OECD

Mathias Cormann took office June 1 as the sixth Secretary-General of the OECD . . .

Americas

US plans tariffs against six nations as digital tax talks heat up

The US Trade Representative on June 2 announced and then immediately delayed implementation of new tariffs on goods from six countries – Austria, India, Italy, Spain, Turkey, and the UK – in response to . . .

Africa

Israel, United Arab Emirates sign tax treaty: Reuters→

Asia-Pacific

South Korea expands R&D tax breaks to bolster semiconductor industry

The Republic of Korea signaled its intention to heavily boost its semiconductor industry with an announcement on May 13 that it will offer up to 50 percent tax credits on research and development (R&D) investment and up to 20 percent . . .

Africa

Kenya tax bill alters permanent establishment definition, increases transfer pricing reporting requirements

Ian Mota, Rödl & Partner, discusses Kenya’s Finance Bill 2021, which includes a new “permanent establishment” definition, country-by-country reporting requirement, and new rules for determining “control” among related entities . . .

Americas

US Treasury ‘Green Book’ details Biden’s international tax plans

May 28, 2021

The US Treasury’s Green Book, released today alongside President Biden’s FY 2022 Budget, outlines the specific tax provisions that the Administration seeks to enact this year, including significant proposals for overhauling . . .

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 . . .

Americas

Key US Republican draws lines for global tax deal

US Senator Mike Crapo (R-Idaho) sent Treasury Secretary Janet Yellen a letter on May 24 outlining potential terms that he would consider acceptable in a global tax deal . . .

Americas

Costa Rica joins OECD

The OECD officially welcomed Costa Rica as its 38th member country on May 25 after it completed the process for ratification of the OECD convention and deposited its instrument of accession . . .

Asia-Pacific

Japan enacts corporate, income, inheritance tax reforms

Takato Masuda of Nishimura & Asahi discusses Japanese corporate, income, and inheritance tax reforms enacted March 26 . . .

Estonia

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

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

Global tax deal should forbid DSTs, equalization levies, and DPTs and should define a broad, uniform tax base for the global minimum tax: Daniel Bunn / Tax Foundation→

May 25, 2021

Americas

G7 reportedly close to deal on new rules for taxing multinationals

May 24, 2021

The G7 group of leading economies is getting close to an agreement to shake up the global rules on the taxation of multinational businesses . . .

Europe

Ukraine’s new transfer pricing reporting forms

May 24, 2021

Yuri Nikolaychuk, Associate Partner, Rödl & Partner, Kyiv, discusses recent updates to Ukraine’s required transfer pricing documentation . . .

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 . . .

OECD

Pillar One compromises to gain US and broader consensus likely mean any agreement would bring limited gains in terms of fairness, efficiency, and administrability, professor says: Aitor Navarro / SSRN→

May 20, 2021

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 . . .

Americas

New Zealand will levy digital services tax on locally-derived revenues of Google, Facebook if no OECD accord is reached, Revenue Minister says: Jonathan Milne / newsroom.pro→

May 20, 2021

Europe

EU report finds states could improve policies on R&D incentives, tax avoidance

May 19, 2021

The European Commission’s Annual Report on Taxation 2021, released May 18, finds that EU member states have made progress in bringing their tax policies in line with EU priorities, but areas for improvement remain . . .

More News

OECD report details its efforts to help developing countries during COVID-19

May 19, 2021

The OECD unveiled a report on May 19 detailing its efforts over the past year to help developing countries create better tax policy measures, maximize revenue collection . . .

Digital Economy

Ambitious EU tax agenda includes new common corporate tax base proposal

May 18, 2021

The European Commission on May 18 announced several proposals that would dramatically alter the taxation of multinational groups, including proposals to allocate MNE profits among EU states using formulary apportionment and require MNEs to publish their effective tax rates . . . .

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 . . .

Africa

If US and EU states can convince large emerging economies to adopt GloBE, MNEs will pay double-digit billions more tax, face increased complexity, Professor says: Joachim Englisch / SSRN→

May 13, 2021

Asia-Pacific

Mongolia rejects mining company’s tax claims in international dispute, seeks damages

May 11, 2021

The government of Mongolia has filed its defense and counterclaim in a USD 155 million international arbitration tax dispute with the operator of the Oyu Tolgai mine, Oyu Tolgai LLC . . .

Americas

US lawmakers reintroduce public country-by-country reporting bill: Rep. Cynthia Axne→

May 11, 2021

Asia-Pacific

Indian court rules most favored nation clause triggered in tax treaty with Netherlands

May 11, 2021

Ritu Shaktawat and Rahul Jain, Khaitan & Co., discuss the High Court of Delhi’s April 22 ruling in a landmark judgment concerning the interpretation of the India-Netherlands tax treaty’s most favored nation clause . . .

Americas

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

May 10, 2021

Americas

Global deal on MNE tax reform likely by October, Saint-Amans tells the French Senate’s finance committee: Reuters→

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 . . .

Digital Economy

UK supports Biden’s global tax deal proposal, with caveats

May 6, 2021

The UK’s primary interest in international tax talks is addressing digital taxation and the allocation of taxing rights under the OECD’s “Pillar One,” but it is okay with the US’s not-digital-only approach to Pillar One, according to Mike Williams . . .

Americas

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

May 6, 2021

Global minimum tax agreement will require substance-based carve-out, Saint-Amans says

May 5, 2021

To reach international agreement, a global minimum tax deal would need to exclude from minimum taxation income from substantive activities within a jurisdiction, according to Pascal Saint-Amans . . .

Americas

Danish High Court rules on beneficial ownership of dividends for tax purposes

May 5, 2021

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses a highly-anticipated High Court of Eastern Denmark ruling issued May 3 that resolves two tax disputes concerning beneficial ownership . . .

Digital Economy

OECD preparing plan to stop unilateral tax measures, Saint-Amans says

The OECD is working on a framework to prevent countries from enacting unilateral tax measures, such as digital services taxes, as part of an agreement under the “Pillar One” negotiations . . .

Africa

OECD’s Global Forum to train African tax officials

The OECD’s Global Forum launched in April its “Train the Trainer” pilot program – a move to provide local training to African tax auditors and investigators . . .

Asia-Pacific

Global minimum tax opponents will not stop agreement, Saint-Amans says

Negotiations on a global minimum tax on corporations have the momentum that they need to reach an agreement now that France, Germany, and others have signaled support for recent US proposals. . .

Digital Economy

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