Inclusive Framework on BEPS

Digital Economy

Digital taxes should remain for companies outside Pillar 1, BEPS Monitoring Group says

October 6, 2021

The BEPS Monitoring Group contends in October 5 comments that multinational enterprises that are not in-scope of the global tax deal’s Pillar 1 partial reallocation of taxing rights to market jurisdictions should remain subject to . . .

Americas

Dominican Republic introduces country-by-country reporting rule – a decade after transfer pricing documentation obligations entered into force

October 5, 2021

José Rafael Monsalve, transfer pricing economist and international tax advisor, discusses the Dominican Republic’s October 5 release of specific regulations for the country-by-country report – a decade after transfer pricing documentation obligations entered into force – through . . .

Africa

Global minimum tax negotiations focus on carve-outs, EU consensus, closing deal

September 30, 2021

Negotiators are seeking to achieve final consensus on the details of the global minimum tax deal, according to September 29 comments from European Commission official Benjamin Angel, with talks centering on the terms for carve-outs and other technical aspects that might bring into the fold remaining . . .

Africa

G-24 warns that global tax deal will fail without better terms for developing countries

September 21, 2021

An international tax agreement on new profit allocation rules and a minimum tax will “not be sustainable even in the medium run” unless the terms allow developing countries to see fair shares under both pillars of the deal, the G-24 contended in September 19 comments submitted . . .

Cyprus

Cyprus to introduce transfer pricing legislation

September 14, 2021

Marios Palesis, T.P. Alfa Services, discusses new transfer pricing legislation that was submitted to the Cyprus parliament in June, defining the persons required to maintain documentation files and report related party transactions, as well describing the type of information . . .

Africa

Togo becomes latest country to endorse global tax reforms

August 31, 2021

The West African nation of Togo became the 140th country to join the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) and the 134th Inclusive Framework member to endorse the two-pillar international tax reform statement released earlier this summer, according to an August 31 . . .

Featured News

Global minimum tax’s ‘GloBE’ maze – more than meets the eye!

August 25, 2021

Noopur Trivedi and Jitesh Golani, international tax researchers, analyze a hypothetical case study evaluating the effect that the intricate rules under the global anti-base erosion (GloBE) proposal in the July 1 OECD/G20 Inclusive Framework statement can have when implemented in a typical multinational . . .

Europe

Germany adopts substantial transfer pricing and anti-treaty shopping rule changes

August 20, 2021

Thomas Schänzle, Christian Port, Florian Gimmler, Justus Eisenbeiß, Christian Witthus, Kevin Prashil Brusa and Rabea Lingier, Baker & McKenzie, analyze the far-reaching, practical implications of the amendments to the anti-treaty-shopping provision and transfer pricing rules in Germany’s Withholding Tax Relief Modernization Act (AbzStEntModG), which took effect June 9 . . .

Americas

Japan releases study group report on international taxation in the digital economy

August 19, 2021

Takato Masuda, Nishimura & Asahi, discusses the August 19 release of the “Study Group on International Taxation in the Digital Economy,” assembled by the Ministry of Economy, Trade and Industry of Japan, providing insight into how the Japanese business sector views the OECD’s two-pillar solution, a digital services tax and . . .

Morocco publishes mutual agreement procedure guide for resolving tax disputes

August 16, 2021

Nour Ali, DNV, discusses Morocco’s Mutual Agreement Procedure (MAP) guide, released July 5 through the General Tax Administration of the Ministry of Economy and Finance, for resolving tax disputes not in accordance with . . .

Asia-Pacific

Gulf Cooperation Council countries and businesses prepare for global minimum tax

August 16, 2021

Raman Ohri, Keypoint, discusses the dilemma that the July 1 inclusive framework agreement on a global minimum tax created for Bahrain, Kuwait, Oman, Qatar, Saudi Arabia, and the United Arab Emirates . . .

Americas

Barbados becomes 133rd country to join global tax agreement, holdouts dwindle to six

August 13, 2021

The agreement on international tax reform that was endorsed by the majority of the 139 “Inclusive Framework” countries on July 1 grew one country stronger on August 12 as Barbados became the latest . . .

Asia-Pacific

Taiwan amends tax treaty rules on residency, permanent establishment, treaty abuse

August 12, 2021

On August 12, Taiwan’s Ministry of Finance promulgated amendments to the regulations governing the application of double tax treaties to update the decade-old rules for developments in international tax trends and conventions, improve administrability, and . . .

Americas

Brazil’s upcoming tax reform will impact inbound investors

August 10, 2021

Luis Felipe de Campos, Rolim, Viotti, Goulart, Cardoso Advogados, discusses the substitute tax reform bill that Brazil’s Ministry of Economy presented to Congress on June 25, including provisions affecting corporate tax rates, profit distributions, interest . . .

Africa

US FDII deduction among international ‘harmful tax practices’ slated to be abolished

August 5, 2021

An update on reviews of preferential tax regimes published by the OECD on August 5 states that the US foreign-derived intangible income (FDII) regime is “in the process of being eliminated.” The new report includes updated conclusions with respect to 18 designated . . .

Asia-Pacific

Russia’s new double tax treaty policy: the score is 3 to 1

August 4, 2021

Roustam Vakhitov, Crowe Expertiza, analyzes Russia’s new tax treaty policy following the government’s June 7 notice to the Dutch government of Russia’s intent to terminate the double tax treaty between the two countries after a failure to . . .

Europe

Germany introduces new administrative principles for transfer pricing

July 23, 2021

Oliver Treidler, TP&C GmbH, discusses Germany’s July 14 release of new administrative principles for transfer pricing that are effective immediately and will constitute a focal point of the German transfer pricing . . .

Europe

Germany adopts ATAD rules on exit taxation, CFCs, hybrids

July 22, 2021

Timo Turek, partner at Ypsilon International GmbH, discusses Germany’s June 30 implementation of the Anti-Tax Avoidance Directive (ATAD) into law, affecting exit taxation, controlled foreign corporation (CFC) taxation reform, intra-EU anti-hybrid rules, as well as . . .

Asia-Pacific

United Arab Emirates publishes MAP guidance for resolving tax and transfer pricing disputes

July 21, 2021

Nour Ali, regional tax consultant at DNV, discusses the United Arab Emirates’ July 1 release of mutual agreement procedure (MAP) guidance for resolving tax and transfer pricing disputes through. . .

Americas

Ireland seeks input on OECD tax proposals’ impact on Irish tax policy

July 20, 2021

The Irish Department of Finance on July 20 opened a consultation on implications for Ireland’s corporate tax policy arising from the two-pillar proposal for overhauling the international tax framework recently . . .

Denmark

Denmark finally implements ATAD amendments to CFC regime

July 19, 2021

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses the Danish parliament’s June 3 passage of a bill to adopt changes to the controlled foreign corporation (CFC) regime necessary for the implementation of the EU Anti-Tax Avoidance Directive (ATAD) . . .

Americas

Mexico’s outsourcing schemes’ demise and its tax and transfer pricing effects

July 19, 2021

Jesús Aldrin Rojas, Managing Partner at QCG Transfer Pricing Practice, discusses tax and transfer pricing considerations for business groups in Mexico following the country’s reform to various tax and labor laws to prohibit outsourcing of personnel, published in the official gazette on April 23 . . .

Africa

Kenya’s Finance Act 2021 amends tax policy approach to global market

July 19, 2021

Samuel Okumu, Tax Consultant at Rödl & Partner Limited, discusses the Kenyan Finance Act 2021, enacted on June 29, which includes numerous amendments to the Income Tax Act, VAT Act and Tax Procedures Act that focus on taxation of cross-border transactions by . . .

Featured News

No global minimum tax holdouts have left negotiations, OECD official notes

July 14, 2021

Speaking virtually at a July 13 Tax Policy Center event, Grace Perez-Navarro, Deputy Director of the OECD’s Centre for Tax Policy and Administration, said the seven countries that have yet to sign onto the statement endorsing the adoption of a global minimum tax have their reasons for holding off, but . . .

Americas

G20 reaffirms tax deal while EU delays digital levy, US eyes legislation

July 12, 2021

The communique issued by the G20 finance ministers at the conclusion of their July 9–10 meeting did not break substantial new ground in international tax talks, but the discussions seemed to help clear a hurdle in helping to . . .

Europe

Italian revenue agency’s new tax assessment guidelines affect multinationals

July 6, 2021

Giuliana Polacco and Annarita De Carne, Studio Legale Bird & Bird, discuss the Italian revenue agency’s May 7 guidelines describing its plans to prevent and fight tax evasion, along with an indication of how it will . . .

Africa

130 nations endorse global tax overhaul, nine nations hold out

July 1, 2021

Following virtual talks between 139 nations represented in the OECD’s “Inclusive Framework,” 130 nations signed onto a detailed statement on July 1 for adopting new international tax rules, including . . .

Africa

G20 draft communique reportedly endorses global minimum tax

June 22, 2021

A draft communique for the upcoming G20 finance ministers meeting on July 9–10 includes language expressing the countries’ support for a global minimum tax and new rules . . .

Europe

Yellen predicts Ireland, EU will cooperate on minimum tax, but US might move first

June 16, 2021

US Treasury Secretary Janet Yellen said today that she has had constructive talks with the Irish finance minister and believes that Ireland – and the entire EU . . .

Asia-Pacific

India has little to gain under G7 tax agreement

June 14, 2021

Suranjali Tandon, National Institute of Public Finance and Policy, discusses how, for developing countries like India, the agreement that the G7 finance ministers reached on June 5 may bring little new tax revenue while imposing . . .

Americas

Professor assesses Pillar One Amount A impact per country, industry: Lorraine Eden / SSRN→

June 7, 2021

Austria

How will the European Commission define shell companies to stop tax avoidance?

June 7, 2021

New York City Economist Dr. J. Harold McClure discusses the European Commission’s launch on May 20 of an initiative to address the use of shell companies in international arrangements . . .

Featured News

OECD should rein in model treaty changes on transfer pricing of financial transactions, commentators say

June 4, 2021

The OECD’s business forum (BIAC) said in a May 28 comment letter that the OECD’s proposed changes to the OECD model tax convention commentary under article 9 relating to the interaction of transfer pricing . . .

Digital Economy

Self-assessment of Spain’s digital services tax postponed until July

May 27, 2021

Alma Delia Virto Aguilar, Postdoctoral researcher at the University of Valencia and Professor, International Taxation LLM, UNIR, discusses the status of Spain’s digital services tax . . .

Africa

Hungary, Ireland, UK reiterate resistance to global minimum tax while Germany remains optimistic

May 26, 2021

Hungary, Ireland, and UK officials have again warned that their countries will not accept the global minimum . . .

Estonia

Greece, Hungary, Iceland fall short of tax dispute resolution goals, OECD review finds

May 26, 2021

Iceland has no bilateral advance pricing agreement (APA) program in place, and Greece, Hungary, and the Slovak Republic are failing to timely resolve mutual agreement procedure (MAP) cases, according . . .

Americas

US agrees to 15% global minimum tax rate, boosting odds for Pillar 2 agreement

May 21, 2021

The US, which has been leading the push for a global agreement on a minimum corporate tax, has proposed a minimum tax rate of 15% – a concession from the 21% rate that the Biden Administration previously . . .

Featured News

BEPS multilateral tax treaty signatories provide interpretation guidelines

May 20, 2021

Issues relating to the interpretation and implementation of the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI) should be resolved under several guiding . . .

Africa

African Tax Administration Forum proposes simpler, more equitable “Pillar One”

May 18, 2021

The African Tax Administration Forum on May 12 sent a revised Pillar One proposal to the OECD Inclusive Framework, emphasizing . . .

Emma Hinson Sims on The Pillar One blueprint — the potential future of international taxation and transfer pricing: “HAPPY BIRTHDAY TO A VERY SMART, BEAUTIFUL, YOUNG LADY ON JANUARY 13TH.” January 6 ,2024

David Valdez on US Tax Court resolves Whirlpool tax dispute involving Mexican maquiladora structure: “Greetings Whirlpool Mexico, I’m trying to contact someone involved with the decision making for transportation from all of your Mexican…” October 20 ,2023

Jose Dominguez on The new US international tax rules: what you need to know about GILTI, FDII, BEAT etc.: “Very informative article. Question. Do you have a software to compute these US International Calcs to make them in house?” April 12 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms Susi, This article is immensely clarifying. I’d like to know whether Danish Supreme Court has already granted its…” March 24 ,2023

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms. Susi, This article is very clarifying. I wonder whether Danish Supreme Court has already granted its decision referred…” March 24 ,2023

May 19 – 20	Tax Council Policy Institute Conference	Washington, D.C.
May 19 – 20	IFA Second European Region Conference	Milan, Italy
May 24	IFA Webinar Series Pillar Two: An Update	Virtual Event
Sept. 4 – 8	IFA Congress	Berlin