OECD–MNE Tax

Africa

Profit shifting persists as corporate tax rates drop 30% in 20 years, OECD study finds

July 29, 2021

The OECD’s annual “Corporate Tax Statistics,” released July 29, reports that the statutory corporate income tax rate in 111 reviewed jurisdictions declined from an average of 28.3% in 2000 to . . .

Americas

Global minimum tax could create confusion with current CFC rules

July 28, 2021

Thomas Locher, Tax Foundation’s Center for Global Tax Policy, discusses how the implementation of a global minimum tax could create confusion with current CFC rules, raising questions about . . .

Africa

Tax dispute peer reviews find Argentine, South African APA programs wanting, Indian MAP issues

July 27, 2021

The latest peer review assessments of countries’ efforts to meet the minimum standard for tax dispute resolution, released by the OECD on July 26, report that both Argentina and South Africa fail the first prong regarding preventing . . .

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

Oman suspends local filing transfer pricing reporting requirement

July 21, 2021

Nour Ali, regional tax consultant at DNV, discusses Oman’s July 7 announcement suspending the country-by-country local filing requirement until . . .

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 . . .

Ireland

Global minimum tax negotiations could land at ‘a bit higher’ rate than 15%, OECD tax director Pascal Saint-Amans says, adding that agreement will proceed with or without Ireland: Irish Times→

July 19, 2021

Multinational

Multinational companies could manipulate financial statements to dodge taxes under OECD proposed tax rules unless issues addressed by accounting reform: Richard Murphy / Tax Research UK→

July 19, 2021

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 . . .

OECD

US nonpartisan agency’s review of Pillars 1 & 2 reports US companies may prefer Pillar 1 adoption to alternative of digital services taxes, while Pillar 2 would allow for more government tax revenues: Congressional Research Service→

July 16, 2021

Multinational

Global minimum tax agreement’s terms – including optional adoption, a substance carve-out, and a rate as low as 15% – mean it may not be robust, strict, and widely-enough adopted to be effective: Michael P. Devereux & John Vella / Oxford University Centre for Business→

July 15, 2021

OECD

Yellen predicts US businesses will press Congress to approve global corporate tax overhaul plans because of the tax certainty such an agreement would offer: Christopher Condon / Accounting Today→

July 14, 2021

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 . . .

New multinational tax allocation rules will ‘overlay’ transfer pricing rules, OECD official says

July 13, 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, explained that the new transfer pricing allocation rules recently endorsed by 130+ countries partially set aside the arm’s length principle but do not . . .

Americas

Latin America tax transparency report finds region committed to tackling tax evasion through implementing tax information exchange standards, but the tools are not yet widely used: OECD→

July 13, 2021

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 . . .

Multinational

OECD ‘brochure’ touts two-pillar international tax reform plan as solution to estimated USD 100-240 billion in revenues that countries worldwide lose annually to corporate tax avoidance: OECD→

July 9, 2021

Americas

Global tax pact gains 131st country, about 80 companies would see profit reallocations

July 6, 2021

The OECD Secretary-General reported July 5 that Peru has become the latest country to join the statement endorsing international tax reform, adding one more country to the . . .

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 . . .

Americas

US tells EU countries digital levy could jeopardize global tax talks

July 1, 2021

The Biden Administration has been reaching out to several European countries, according to June 30 reports, asking them to press the European Commission to put off a digital levy proposal that could. . .

Digital Economy

G7 global minimum tax deal leaves open questions

June 30, 2021

Vasiliki Koukoulioti, PhD researcher at Queen Mary University of London, discusses the questions that still surround the details of the global minimum tax agreement that G7 finance ministers reached on June 5 . . .

Africa

Irish tax treaty commentators disagree on approach to new negotiations

June 23, 2021

Comments from business groups and non-governmental organizations, published June 21, in response to Ireland’s public consultation on its tax treaty policy identified several jurisdictions where . . .

Americas

New OECD toolkit guides Latin American and Caribbean tax authorities on applying value-added tax to e-commerce activities: OECD→

June 23, 2021

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 . . .

Digital Economy

OECD develops exchange framework for digital platform tax reporting

June 22, 2021

The OECD sets out in a June 22 report a multilateral competent authority agreement for the automatic exchange of information relating to income derived by . . .

China

China may not have much to lose under global corporate minimum tax and could hinge its support on US’s willingness to lift tariffs on Chinese goods: Frank Tang / South China Morning Post→

June 21, 2021

Ireland

Ireland will seek yet-to-be-defined compromise in global minimum tax talks with aim of preserving room for tax competition by smaller countries, Irish Finance Minster says: Silvia Amaro / CNBC→

June 21, 2021

Europe

Finnish tax administration publishes statements addressing transfer pricing guidelines and effect of COVID-19 on permanent establishment rules

June 16, 2021

Ville Alahuhta, Bird & Bird Attorneys Ltd, discusses the Finnish tax administration’s April 19 and 21 guidance clarifying its position on the retroactive effect of updates to the OECD transfer pricing guidelines and the effects of COVID-19 . . .

Europe

EU will propose minimum tax legislation if G20 reaches deal, commissioner says

June 14, 2021

The European Commission will propose legislation to implement an international agreement on a global minimum corporate tax to ensure its uniform application within the EU, according to June 14 . . .

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 . . .

OECD

UK finance minister Rishi Sunak seeks agreement on financial services exemption from global minimum tax: Emma Agyemang, George Parker, Chris Giles / Irish Times→

June 10, 2021

Europe

Ukraine implements mutual agreement procedure for resolving tax disputes

June 10, 2021

Viktoriia Bublichenko, GOLAW, discusses the Ukraine finance ministry’s March 26 decree establishing the detailed order of conduct of the mutual agreement procedure (MAP) for resolving international tax disputes . . .

Americas

G7 tax breakthrough sets stage for G20 talks in July, issues remain

June 7, 2021

G7 finance ministers reached a momentous agreement on June 5 on a global corporate minimum tax and changes to the allocation of taxing rights between . . .

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 . . .

Americas

Perú tax authority considerations about the use of multi-year data in determining arm’s length transfer pricing

June 7, 2021

Zaida Limongi, TP Consulting Perú, discusses the Peruvian tax administration’s April 15 transfer pricing guidance . . .

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