Inclusive Framework on BEPS

Americas

India may oppose US proposal to tax only top 100 companies: Dilasha Seth / Business Standard→

May 10, 2021

Europe

Ukraine tax authorities adopt new rules for nonresident registration

May 7, 2021

Iryna Kalnytska, GOLAW, discusses Ukrainian tax guidance concerning foreign (non-resident) companies that must register with Ukrainian tax authorities . . .

Americas

Professor breaks down US strategy in Pillar 1 & 2 negotiation: Michael P. Devereux / Oxford→

May 6, 2021

Digital Economy

UN versus OECD – It’s time for the UN to get going

May 4, 2021

Kuldeep Sharma, ADIT (CIOT, UK), discusses why it’s time for the UN to come out of the shadows of the OECD, make structural changes to its tax committee and strengthen its Secretariat to bring it at par with the OECD . . .

Americas

Global agreement on new nexus rules and minimum tax likely by October, Saint-Amans says

April 22, 2021

Momentum is quickly growing for agreement on the final policy approach for new international tax rules on country taxing rights under the OECD’s “Pillar One” . . .

Asia-Pacific

Maldives publishes advance pricing arrangement regulations

April 22, 2021

Zaina Zahir, CTL Strategies, discusses the Maldives Inland Revenue Authority’s advance pricing arrangement regulations published on March 16 . . .

Europe

Ireland positions itself as counterpoint to US in debate over global minimum tax

April 21, 2021

Irish Finance Minister Paschal Donohoe today confirmed that Ireland would resist the push for a global minimum tax to the extent that it would infringe on the country’s 12.5 percent corporate tax rate . . .

Europe

UK tables amendments to hybrid rules

April 20, 2021

The UK government, on April 15, tabled for the Committee of the Whole House amendments to Finance Bill 2021 relating to the corporate tax rules on hybrids and other mismatches . . .

Americas

Canada’s 2021 budget includes proposals on digital taxes, profit shifting, interest deductibility

April 20, 2021

Canada’s Budget 2021, presented by Finance Minister Chrystia Freeland on April 19, proposes several significant tax measures affecting multinational enterprises . . .

Americas

Ireland, Mexico among countries struggling to timely resolve MAP tax and transfer pricing cases

April 19, 2021

Five of eight countries in the OECD’s latest round of peer review reports failed to resolve mutual agreement procedure (MAP) cases within the average 24-month timeframe sought by the OECD . . .

Americas

Groups criticize UN model tax treaty software proposal but for different reasons

April 14, 2021

Trade and civil society groups are critical of a proposal to revise the UN model tax treaty to include software payments within the definition of royalties. . .

Europe

Ireland reevaluating tax treaty policy

April 13, 2021

The Irish Department of Finance opened a public consultation on the country’s overall tax treaty policy on April 7 with an eye to adapting to OECD recommendations and ongoing . . .

Asia-Pacific

India reduces transfer pricing filing burdens, increases reporting thresholds

April 13, 2021

Gaurav Jain, Chartered Accountant, and Priya Bhutani, New Delhi, India, discuss April 5 amendments to India’s transfer pricing guidance relating to the master file and country-by-country reporting . . .

Africa

Insight into the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation

April 8, 2021

Parwin Dina, Lead Client Service Partner and Global Tax Leader, GTS (Global Tax Services) UAE, examines the Platform for Collaboration on Tax’s toolkit on transfer pricing documentation . . .

Europe

G20 ministers renew call for consensus over MNE taxation

April 7, 2021

G20 finance ministers and central bank governors on April 7 renewed their call on for agreement on new tax rules for multinational groups. . .

Digital Economy

OECD Secretary-General report to G20 ministers includes overview of 66 countries’ tax policy responses to COVID-19: OECD→

April 7, 2021

Antigua and Barbuda

Countries continue to permit tax treaty shopping despite BEPS promises

April 6, 2021

Most countries are not fulfilling their commitment to amend their tax treaties to meet global standards aimed at preventing tax avoidance through tax treaty shopping, an April 1 OECD report shows. . .

Americas

Tax havens begin sharing information about entities that earn income from IP, other mobile activities

March 31, 2021

Twelve tax haven countries, for the first time, provided information about the activities of some business entities located in their countries to the countries where the entities’ parents or beneficial owners are tax residents, the OCED today announced. Anguilla, the Bahamas . . .

Proposed OECD model tax treaty updates cover transfer pricing for interest payments, corresponding adjustments

March 31, 2021

The OECD on March 29 proposed changes to its model tax convention commentary that would alter language regarding the arm’s length treatment of interest payments between associated enterprises located in different countries and clarify a state’s obligation . . .

Europe

Greece and Hungary join BEPS MLI to fight multinational group tax avoidance

March 31, 2021

Greece and Hungary have deposited their ratification instruments for the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (BEPS MLI), the OECD announced March 30. . .

Digital Economy

EU Parliament committee adopts resolution on digital taxation

March 30, 2021

The European Parliament’s Committee on Economic and Monetary Affairs (ECON) on March 23 adopted a motion for a European Parliament resolution on digital taxation, OECD negotiations, tax residency of digital companies, and a possible European digital tax. . .

Asia-Pacific

US multinationals tax payments halved, investment and revenues boosted following 2017 tax overhaul, JCT report finds

March 24, 2021

US MNEs paid substantially lower corporate taxes following the 2017 Tax Cut and Jobs Act, both domestically and globally, a March 19 report from the US congressional Joint Committee on Taxation concludes. . .

Asia-Pacific

Singapore adopts BEPS-compliant IP tax incentives

March 24, 2021

Edmund Leow SC of Dentons Rodyk & Davidson LLP, Singapore, discusses Singapore regulations on its new concessionary income tax rules for intellectual property, which came into effect on January 22. . .

Asia-Pacific

Mongolia issues first transfer pricing assessment

March 18, 2021

The Mongolian government has issued its first transfer pricing tax assessment, hitting a mining company with a tax bill of approximately USD 228 million and a denial of USD 1.5 billion in carried forward . . .

Inclusive Framework on BEPS

NGOs dispute UN proposal deeming software payments as royalties, arguing it would perpetuate a confused notion of “copyright,” retroactively diminishing state taxing rights: BEPS Monitoring Group→

March 18, 2021

Americas

Can GILTI and the GloBE be harmonized in a Biden administration?

March 3, 2021

Daniel Bunn, Vice President of Global Projects, Tax Foundation, discusses the need for the US’s GILTI rules and the Inclusive Framework’s GloBE proposal to be harmonized . . .

Digital Economy

Is the EU (unintentionally) undermining ongoing OECD work on digital taxation?

February 17, 2021

Oliver Treidler, TP&C GmbH, discusses the January 14 European Commission inception impact assessment and request for public feedback on the design of an EU digital levy . . .

Africa

OECD publishes assessment of cross-border tax dispute resolution in 13 more countries

February 17, 2021

The OECD on February 1 published assessments of the cross-border tax dispute resolution processes in Aruba, Bahrain . . .

Practical obstacles prevent low-income countries from participating in global tax standard-setting through Inclusive Framework, authors say: Rasmus Corlin Christensen, Martin Hearson, & Tovony Randriamanalina / The International Centre for Tax and Development→

December 21, 2020

Africa

OECD releases 250+ comment letters on pillar one and two blueprints

December 16, 2020

The OECD today released more than 250 comment letters in response to a request for public . . .

Africa

Peer review report on exchange of information on tax rulings finds 81 nations fully compliant with minimum standards, makes recommendations for 42 others: OECD / Inclusive Framework→

December 15, 2020

Inclusive Framework on BEPS

Professor concludes that the OECD pillar one & two proposals would be significant reform that responds to identified flaws in the international tax system: Craig Elliffe / SSRN→

November 30, 2020

Africa

18 more nations meet global standards on countering harmful tax practices, OECD says

November 25, 2020

Hong Kong, Switzerland, and Mauritius are among 18 jurisdictions that now meet global “minimum standards” on harmful tax practices, the OECD announced . . .

Africa

G20 leaders again pledge to reach international tax deal

November 23, 2020

The Leaders of the world’s 20 biggest economies have again committed to work toward reaching a political agreement on revised rules . . .

Europe

Swiss government approves protocols to Liechtenstein, Malta, Cyprus tax treaties

November 12, 2020

Switzerland’s Federal Council, at its November 11 meeting, approved . . .

OECD releases new methodology for peer review of country-by-country reporting minimum standard

October 29, 2020

The OECD today released a new methodology for judging whether 137 countries and their tax administrations have met minimum standards . . .

Asia-Pacific

OECD releases report assessing tax dispute resolution in Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, Spain

October 22, 2020

The OECD today released stage 2 peer review reports that assess compliance with global minimum standards on cross-border tax dispute resolution . . .

Digital Economy

OECD’s pillar 1 & 2 impact assessment reveals the value of reaching global agreement versus descending into a tax and trade wars: Daniel Bunn / Tax Foundation→

October 21, 2020

Digital Economy

G20 ministers vow to continue work on international tax rewrite

October 14, 2020

In a communique released after their October 14 virtual meeting, G20 finance ministers and central bank governors said they remain committed to achieving consensus . . .

Khaled Al Zaabi on Spanish government proposes digital services tax: “We are seeking assistance with Digital Assets and International Tax Consulting to help Abu Dhabi UAE Oil Company navigate the…” October 24 ,2024

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

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