OECD–MNE Tax

Multinational

Tax Inspectors Without Borders has helped developing countries bring in more than USD 1 billion in additional tax revenues: OECD→

April 29, 2021

Denmark

Denmark Supreme Court rules in Tetra Pak transfer pricing case

April 29, 2021

Susi Baerentzen, Carlsberg Foundation Postdoctoral Fellow, discusses the Danish Supreme Court’s April 26 ruling in a landmark transfer pricing case involving a Danish company Tetra Pak that produced and sold plants for manufacturing ice cream . . .

Europe

EU preferential regimes and Code of Conduct Group: state of play

April 28, 2021

Francesca Amaddeo, Tax Law Competence Centre (SUPSI), discusses several developments in April regarding the EU Code of Conduct Group’s effort to rein in tax avoidance . . .

Europe

Spanish guidance clarifies transfer pricing arm’s length range

April 28, 2021

Mario Ortega and Íñigo García, J&A Garrigues, S.L.P., discuss Spain’s February 24 transfer pricing guidance on arm’s length price . . .

Europe

EU’s digital levy proposal to run parallel to OECD talks, Commission official confirms

April 23, 2021

The EU’s proposed digital levy would be in addition to any agreement on taxing large digital companies that arises from OECD talks this year, but the levy will be modest, according to Benjamin Angel, the European Commission’s Director of Direct Tax Policy and acting Director of Indirect Tax Policy. Speaking . . .

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” . . .

Europe

Poland clarifies its unique definition of “controlled transaction” for transfer pricing purposes

April 22, 2021

Dr. Monika Laskowska, Center of Tax Analyses and Studies, discusses Poland’s early April launch of a public consultation on new transfer pricing guidance defining controlled transactions . . .

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 . . .

Digital Economy

OECD report looks at impact of digitalization of tax administrations in dealing with the COVID-19 crisis, assessing taxpayer services, compliance risk management, remote working, IT systems, support for wider government: OECD→

April 21, 2021

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 . . .

Digital Economy

Digital platforms should assist tax compliance efforts, OECD says

April 20, 2021

The digital platforms that have fueled the growth of the sharing and gig economies have a role to play in value-added tax (VAT) and goods and services tax (GST) compliance and administration, the OECD said . . .

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 . . .

Europe

OECD names new chair of international tax policy body

April 19, 2021

The OECD announced on April 16 that it appointed Fabrizia Lapecorella as the new head of the Committee on Fiscal Affairs starting on January 1, 2022. . .

More News

International Compliance Assurance Programme (ICAP) FAQs provided: OECD Forum on Tax Administration→

April 18, 2021

Americas

Wyden says Treasury’s OECD proposal would address digital taxes that discriminate against US companies while supporting US tax reform goals: US Senate Committee on Finance→

April 14, 2021

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. . .

Americas

NGO proposal revises minimum tax to overcome OECD approach’s shortcomings

April 14, 2021

The proponents of a new minimum effective tax rate proposal for multinational corporations say their proposal would modify the OECD’s proposed global anti-base erosion tax (GloBE) . . .

Americas

US support for R&D has stalled relative to France, UK, others

April 14, 2021

While several countries have significantly boosted their support for business research and development (R&D) relative to their overall economies in recent years, total US government support for business R&D . . .

G20

Higher carbon pricing through carbon taxes, emissions trading systems, and fuel excise taxes is needed to meet climate objectives, IMF/OECD report concludes: OECD→

April 13, 2021

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 . . .

Americas

Countries should suspend their DSTs now to show they are serious about reaching global agreement on international tax, ranking member says: US Senate Finance Committee→

April 13, 2021

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

Leaked copy of US proposal for Pillar One and Two multinational group tax reforms available

April 12, 2021

MNE Tax has obtained a copy of a slide presentation outlining the US’s latest “Pillar One” and “Pillar Two” proposals for the reform of the international system for multinational group taxation. . .

Europe

Spanish finance minister says Spain favors global minimum corporate tax, presents committee with broad tax reforms to bolster revenue: Explica.co→

April 12, 2021

Americas

Cyprus divided on Yellen’s minimum corporate tax: Andrew Rosenbaum / CyprusMail→

April 9, 2021

Africa

US offers new “Pillar One” compromise plan for taxing large multinationals

April 8, 2021

The Biden administration has proposed a new “Pillar One” scheme for taxing multinational groups to a coalition of 139 countries . . .

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

Multinational

Professor analyzes OECD model treaty changes regarding entitlement to tax treaty benefits for income received through transparent entities: Leopoldo Parada / SSRN→

April 6, 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

MNEs shifted USD 1 trillion in profits offshore to tax havens, ICIJ study says: Scilla Alecci / International Consortium of Investigative Journalists→

April 5, 2021

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. . .

Americas

US threatens tariffs against six more nations over digital taxes, drops investigation into others

March 29, 2021

The US Trade Representative has recommended trade actions against Austria, India, Italy, Spain, Turkey, and the UK following its findings that digital services taxes adopted by these countries discriminate against US companies. . .

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