OECD–MNE Tax

Americas

13 trade associations object to India’s proposed equalisation levy expansion

March 26, 2021

A global group of 13 technology and business trade associations sent a letter on March 19 to the Indian Parliament urging it not to adopt amendments to the equalisation levy announced in the government’s proposed Finance Bill 2021–22. . .

Africa

OECD details 30 countries’ approach to cross-border tax dispute arbitration

March 25, 2021

The OECD today added information to its website on 30 countries’ processes for arbitrating cross-border tax . . .

Europe

UK consults on aligning transfer pricing documentation requirements with OECD approach

March 24, 2021

The UK HM Revenue and Customs is considering potential new transfer pricing documentation requirements that would require businesses to prepare and provide specific documentation to support their transfer pricing . . .

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’s first transfer pricing assessment – what could be the issues?

March 23, 2021

Dr. J. Harold McClure, New York economist, discusses the issues surrounding Mongolia’s first transfer pricing assessment. . .

Asia-Pacific

Bahrain introduces country-by-country reporting requirements

March 23, 2021

Abdulrahman Bucheeri and Raman Ohri of Keypoint Solutions, Manama, discuss Bahrain ministerial guidance introducing country-by-country reporting requirements, released on February 4 . . .

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

Mathias Cormann appointed OECD Secretary General

March 17, 2021

The OECD council on March 15 named former Australian finance minister Mathias Cormann as its next leader beginning in June. He will become the first secretary-general from. . .

Africa

EU to implement digital levy regardless of OECD-led effort

March 16, 2021

The EU Commission will continue to press ahead with its proposal for an EU digital levy to fund EU operations even if a global international tax . . .

Asia-Pacific

Australia to amend its offshore banking unit regime to avoid OECD, EU tax haven blacklists, treasurer says: Australian Treasury→

March 15, 2021

“Platform for Collaboration on Tax” toolkit offers guidance on negotiating tax treaties

March 11, 2021

On March 10, the “Platform for Collaboration on Tax” – a joint initiative of the IMF, OECD, UN, and World Bank Group – launched the final version of its Toolkit on Tax Treaty Negotiations. . .

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 . . .

Africa

Zambia introduces country-by-country reporting

March 3, 2021

Rubeena Dina and Kennedy Munyandi, of GTS Africa, discuss the Zambian government’s issuance of transfer pricing regulations addressing country-by-country reporting, which became effective January 1 . . .

G20

OECD releases secretary-general tax report to G20 finance ministers and central bank governors: OECD→

February 26, 2021

Africa

US drops demand that “pillar one” global tax compromise be a safe harbor

February 26, 2021

The US will no longer require that any coordinated “Pillar One” update to the international tax and transfer pricing rules be drafted as a “safe harbor.” The announcement . . .

Multinational

OECD reports on strategies to crack down on professionals who enable tax and white collar crimes: OECD→

February 26, 2021

Europe

ActionAid, Christian Aid Ireland, Oxfam call on Ireland to drop opposition to public country-by-country reporting: Naomi O’Leary / The Irish Times→

February 24, 2021

G20

Biden Deputy Treasury nominee seeks higher corporate tax rates, level playing field for American companies, ending global corporate tax ‘race to the bottom’: Reuters→

February 24, 2021

Africa

Countries agree to new rules for private tax ruling transparency

February 22, 2021

An OECD-led coalition of 139 countries working together on cross-border tax issues known as the “Inclusive Framework on BEPS” has agreed to a new method for assessing whether countries meet global minimum standards for private tax ruling . . .

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 . . .

Africa

Stakeholders weigh-in on BEPS Action 14 standards for cross-border tax dispute resolution

February 10, 2021

Parwin Dina, Lead Client Service Partner and Global Tax Leader, GTS (Global Tax Services) UAE, discusses an OECD consultation meeting, held February 1, addressing OECD Secretariat proposals with respect to a 2020 review of BEPS Action 14, concerning cross-border tax dispute resolution . . .

Multinational

Using a novel measurement approach, professors conclude that Pillar One and Two blueprint rules are more complex than existing OECD and UN transfer pricing guidance: Jean-Edouard Colliard, Lorraine Eden, & Pierre Georg / SSRN→

February 8, 2021

Africa

First Look: OECD consultation focuses on improving cross-border tax dispute resolution

February 1, 2021

The OECD today hosted a consultation meeting on a planned review of minimum standards, agreed to by OECD and G20 countries in 2015, that aim to improve cross-border tax dispute resolution for multinational . . .

Americas

COVID-19 and tax treaties: the updated OECD guidance

January 27, 2021

Parwin Dina, Lead Client Service Partner and Global Tax Leader at GTS (Global Tax Services) UAE, discusses the OECD’s updated guidance on COVID-19 and tax issues, issued January 21 . . .

Africa

New report suggests ways that developing countries can reform energy taxes: OECD→

January 25, 2021

Americas

US Treasury nominee Yellen supports 28% corporate rate, 15% min tax on booked income, global min tax; pledges to work with OECD/G20 to resolve digital tax dispute: Reuters→

January 25, 2021

Estonia

Estonia joins BEPS multilateral tax treaty

January 19, 2021

Estonia deposited its instrument of ratification for the Multilateral Convention to Implement Tax Treaty . .

Africa

“Platform for Collaboration on Tax” toolkit helps countries set up transfer pricing documentation regimes

January 19, 2021

The “Platform for Collaboration on Tax,” a joint initiative of the IMF, OECD, UN, and World Bank Group today released a toolkit aimed at helping developing countries establish an effective transfer pricing . . .

Americas

Day 2 of OECD consultation on international tax reform blueprints: Daniel Bunn / Tax Foundation→

January 19, 2021

Americas

Day 1 of OECD consultation on international tax reform blueprints: Daniel Bunn / Tax Foundation→

January 19, 2021

Americas

OECD adds transfer pricing country profiles for Argentina, Dominican Republic: OECD→

January 15, 2021

Africa

Arm’s length principle mutations: control of risk in the OECD guidelines and variations in practice

January 13, 2021

Andrew Hickman, UK consultant and former OECD Transfer Pricing Head, observes that a “mutated” form of the arm’s length principle is being applied in practice that differs from the 2017 OECD transfer pricing guidelines, and considers whether the guidelines should adopt these changes or if these mutations should be abolished . . .

Africa

OECD releases 20 comments on BEPS Action 14, new tax dispute resolution proposals

January 13, 2021

The OECD today released 180+ pages of public comments from 20 groups responding to a planned 2020 review of Action 14 of the OECD/G20 base erosion . . .

Africa

OECD plans public consultation meeting on “blueprints” for taxing large multinationals

January 6, 2021

The OECD has announced that it will hold public consultation meetings on the Report on the Pillar One Blueprint and the Report on the Pillar Two Blueprint. The meetings are scheduled for . . .

Africa

OECD offers helpful guidance on transfer pricing aspects of the pandemic

December 21, 2020

Economist Dr. J. Harold McClure, New York City, takes a detailed look at December 18 OECD guidance addressing difficult transfer pricing issues that multinationals may face due to the current pandemic . . .

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

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