OECD–MNE Tax

Albania

Albania, Bosnia and Herzegovina, Costa Rica join BEPS MLI, France adds more treaties

September 23, 2020

Albania, Bosnia and Herzegovina, and Costa Rica have deposited their instruments of ratification . . .

Africa

Revised (Sept 16) draft pillar one and two digital tax blueprints now available

September 23, 2020

The international tax community needs to again thank McGill Professor Allison Christians for getting ahold of leaked copies of the latest versions of the pillar one and pillar two digital tax . . .

Africa

EU may address public country-by-country reporting this year, German minister says

September 21, 2020

The EU may soon take up the issue of whether country-by-country reports detailing the tax affairs of large multinationals should be made public, German Federal Minister of Finance Olaf Scholz said today . . .

Asia-Pacific

Tax Inspectors Without Borders, a joint OECD/UNDP initiative, has launched its first program in Kazakhstan: TIWB / Twitter→

September 17, 2020

Digital Economy

EU will propose its own digital tax plan if global agreements “fall short of a fair tax system that provides long-term sustainable revenues,” President von der Leyen says: European Commission→

September 16, 2020

Digital Economy

EU to propose digital tax by June 2021 if OECD process fails, official says: Valdis Dombrovskis / EU Commission→

September 14, 2020

Americas

Pillar 2 is a big threat to Bermuda re/insurers, trade group rep says: Intelligent Insurer→

September 14, 2020

Africa

UN model treaty proposal would impose withholding tax on software payments

September 9, 2020

Jian-Cheng Ku and Xander Stubenrouch of DLA Piper Nederland N.V., Amsterdam, discuss a September 1 discussion draft under consideration by the UN Committee of Experts on International Cooperation in Tax Matters which proposes an amendment the UN model tax convention to include software payments in the definition of royalties . . .

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Africa

Leaked OECD draft pillar one and pillar two digital tax blueprints available

September 3, 2020

McGill University professor, Allison Christians, today published the full text of the OECD pillar one and pillar two blueprints . . .

OECD publishes tax information exchange reviews for Anguilla, Chile, China, Gibraltar, Greece, Korea, Malta, Papua New Guinea, Uruguay: OECD→

September 3, 2020

Africa

Taxing somewhere, no matter where: what is the GLoBE proposal really about

September 2, 2020

Dr. Leopoldo Parada a lecturer at the University of Leeds School of Law, UK, makes the case for rejecting the global anti-base erosion proposal, also known as “GloBE,” introduced into the international tax debate by the OECD . . .

Digital Economy

UN subcommittee advances model tax treaty article on automated digital services

August 31, 2020

A UN Committee of Experts on International Cooperation in Tax Matters subcommittee has concluded that the drafting group developing proposed UN model tax treaty Article 12B, addressing the taxation of automated. . .

Americas

Covid-19 has accelerated foreign governments’ need to collect tax revenue from digital giants and the risk of US-led trade war: Vijay Govindarajan, Anup Srivastava , Hussein Warsame, & Luminita Enache / Harvard Business Review→

August 25, 2020

Airbnb backs OECD approach to digital services tax: Reuters→

August 13, 2020

Asia-Pacific

India issues comprehensive guidance on cross-border tax dispute resolution

August 11, 2020

Ritu Shaktawat, Partner, and Raghav Kumar Bajaj, Principal Associate, at Khaitan & Co, Mumbai, discuss India guidance, released August 7, on the procedure for resolving cross-border tax disputes under the mutual agreement procedure (MAP) set out in India’s tax treaties with other nations . . .

Multinational

OECD working paper concludes that, rather than being regressive, VAT is roughly proportional or slightly progressive in most of the 27 OECD countries examined: OECD→

August 11, 2020

Americas

Public input sought on Brazil, OECD transfer pricing harmonization

August 7, 2020

Francisco Moreira, a Partner, Bocater Advogados, São Paulo, Brazil, discusses a July 30 request made by the OECD and Brazil’s tax authority, Receita Federal, for the public to contribute to research regarding harmonizing the Brazilian transfer pricing legislation with the OECD transfer pricing guidelines . . .

Americas

UN committee proposes new model treaty provision altering taxation of automated digital services

August 6, 2020

The UN Committee of Experts on International Cooperation in Tax Matters today released a proposed optional UN model tax treaty article that would grant additional taxing rights to countries where an automated digital services provider’s customers . . .

Africa

Global Forum publishes toolkit to help countries join global treaty providing for cooperation in tax matters: Global Forum on Transparency and Exchange of Information for Tax Purposes→

July 31, 2020

Multinational

OECD again updates listing of tax policy measures enacted in response to COVID-19: Twitter / OECDtax→

July 31, 2020

International Monetary Fund

PCT webinar addressing new Toolkit on Taxation of Indirect Transfers features presentations by OECD, IMF officials: Platform for Collaboration on Tax→

July 30, 2020

Africa

OECD reports assess cross-border tax dispute resolution in Andorra, Bahamas, Bermuda, BVI, Cayman Islands, Faroe Islands, Macau, Morocco, Tunisia

July 30, 2020

The OECD on July 27 published reports approved by a group of 135+ countries known as the “Inclusive Framework on BEPS” that assess . . .

Africa

G20 finance ministers again pledge to agree on new multinational group tax rules by year-end

July 20, 2020

In a communique released after their July 18 virtual meeting, G20 finance ministers and central bank governors said that despite the disruptions created by the COVID-19 pandemic, they . . .

Multinational

The PCT, a joint IMF, OECD, UN, World Bank tax initiative, publishes 2020 progress report: Platform for Collaboration on Tax→

July 10, 2020

Africa

New OECD country-by-country reporting statistics offer insight into multinational group tax avoidance behavior

July 8, 2020

Susi Baerentzen, an Industrial Ph.D. Student at Innovation Fund Denmark discusses the OECD’s July 9 release of data on 4,000+ MNE groups . . .

Africa

OECD publishes model rules for tax reporting by gig economy platform operators

July 8, 2020

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, discusses the OECD’s July 3 release of model rules for tax reporting by platform operators. . .

Asia-Pacific

Oman deposits instrument of ratification of BEPS MLI: OECD→

July 7, 2020

Americas

US has not pulled out of digital tax talks, OECD’s Gurria says: Leigh Thomas / Reuters→

July 1, 2020

Africa

Draft toolkit on the art of tax treaty negotiation offers tips for developing countries

July 1, 2020

Francesca Amaddeo, a researcher at the Tax Law Competence Centre (SUPSI), Manno, Switzerland, writes about a draft toolkit for tax administrations on tax treaty negotiation published on June 29 by the Platform for Collaboration on Tax, which is a joint initiative of the IMF, OECD, UN, and World Bank Group (WBG) . . .

Multinational

OECD updates database of country tax policy measures in response to the COVID-19 crisis: OECD→

June 30, 2020

Belgium

Belgium parliament digital tax hearing considers effect of reforms on patent box, features negotiation update by Pascal Saint Amans: Johan Bernardo Langerock / Twitter→

June 30, 2020

Digital Economy

BIAC reiterates commitment to OECD project to address the tax challenges of the digitalization of the economy: Business at OECD→

June 26, 2020

Africa

The OECD’s “no Plan B” approach on digital taxation backfires

June 22, 2020

Oliver Treidler, CEO of TP&C GmbH, Berlin, discusses the breakdown of global digital tax talks and the likely future of negotiations . . .

Americas

OECD-led rewrite of international tax rules should not be rushed given COVID-19, US tax-writing lawmakers say: The United States Senate Committee on Finance→

June 19, 2020

International Monetary Fund

PCT to run workshops on toolkits for tax authorities: Platform for Collaboration on Tax→

June 19, 2020

Americas

OECD to stick to digital tax negotiation timetable despite US opposition

June 18, 2020

The OECD today confirmed that it will continue its work developing a multilateral approach to the taxation of the digital economy before . . .

Americas

US has abandoned negotiations with EU on digital tax, proposes pausing OECD-led negotiations, US officials say: Andrea Shalal / Reuters→

June 17, 2020

Africa

Transfer prices based on EBITDA, not EBIT

June 17, 2020

Dr. Ednaldo Silva, Founder & Director at RoyaltyStat, discusses whether transfer pricing analysis of operating profits should be based on EBITDA or EBIT . . .

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