Multinational

Africa

G20 leaders again pledge to reach international tax deal

November 23, 2020

The Leaders of the world’s 20 biggest economies have again committed to work toward reaching a political agreement on revised rules . . .

Africa

OECD proposes revised “minimum standards” for nations on cross-border tax dispute resolution

November 19, 2020

The OECD Secretariat has requested public feedback on proposals designed to strengthen the Action 14 minimum standards on cross-border tax dispute . . .

Africa

Cross-border tax disputes continued to rise in 2019, new OECD stats say

November 18, 2020

Despite the efforts of the OECD and others enhance tax certainty, the number of new tax disputes between multinational groups . . .

Africa

Zambia’s transfer pricing advances and the Mopani copper mine dispute

November 16, 2020

Dr. J. Harold McClure, New York City, discusses a November 12 OECD case study on Zambia’s landmark Supreme Court victory in a transfer pricing dispute involving the Mopani copper mines and notes transfer pricing issues addressed and not addressed in the Court’s decision . . .

Professors assess 14 proposals to tax the “cooperative surplus” of highly digitalized MNEs, say DSTs should be treated as creditable withholding taxes: Allison Christians & Tarcisio Diniz Magalhaes / SSRN→

November 13, 2020

Europe

Swiss government approves protocols to Liechtenstein, Malta, Cyprus tax treaties

November 12, 2020

Switzerland’s Federal Council, at its November 11 meeting, approved . . .

Digital Economy

UN to add automated digital services article to model tax treaty

November 9, 2020

The UN Committee of Experts on International Cooperation in Tax Matters has agreed to add . . .

Americas

Panama becomes 56th nation to finalize MLI

November 5, 2020

Panama has deposited its instrument of ratification for the . . .

Africa

Burkina Faso deposits BEPS MLI ratification documents with OECD

November 3, 2020

The OECD has announced that Burkina Faso on October 30 deposited instruments . . .

Americas

Peru to exchange tax information on companies and individuals with other nations

November 2, 2020

Yasser Zola, Transfer Pricing Manager at BaseFirma Peru, Lima, notes that according to an October 19 Peru tax authority announcement, Peru will soon begin exchanging tax information with other countries . . . .

OECD releases new methodology for peer review of country-by-country reporting minimum standard

October 29, 2020

The OECD today released a new methodology for judging whether 137 countries and their tax administrations have met minimum standards . . .

Multinational

New report discusses tax policy issues associated with virtual currencies: OECD→

October 28, 2020

Multinational

UN tax subcommittee PowerPoint shows plan for new handbook for policymakers on carbon tax: United Nations→

October 28, 2020

Digital Economy

Author proposes international taxation regime for cross border cloud computing businesses: Alexander Weisser / UNIGE→

October 27, 2020

Africa

Transfer pricing in Kenya: beyond Unilever

October 22, 2020

New York economist Dr. J. Harold McClure discusses the new Kenya chapter in the United Nations Practical Manual on Transfer Pricing for Developing Countries and Kenya’s loss in a transfer pricing dispute with Unilever . . .

Asia-Pacific

OECD releases report assessing tax dispute resolution in Czech Republic, Denmark, Finland, Korea, Norway, Poland, Singapore, Spain

October 22, 2020

The OECD today released stage 2 peer review reports that assess compliance with global minimum standards on cross-border tax dispute resolution . . .

Digital Economy

OECD’s pillar 1 & 2 impact assessment reveals the value of reaching global agreement versus descending into a tax and trade wars: Daniel Bunn / Tax Foundation→

October 21, 2020

Africa

The UN transfer pricing manual’s updated China chapter: wine and smartphones

October 20, 2020

Dr. J. Harold McClure, a New York City economist, discusses the newly revised China chapter of the United Nations Practical Manual on Transfer Pricing for Developing Countries, released in advance of the 21st session of Committee of Experts on International Cooperation in Tax Matters . . .

Africa

UN tax committee to consider adding new automated digital services article to model convention

October 20, 2020

Jian-Cheng Ku and Xander Stubenrouch of DLA Piper Nederland N.V., Amsterdam, discuss the UN Committee of Experts on International Cooperation in Tax Matters plans to consider at its 21st session a proposed new model tax convention article that addresses automated digital services income . . .

Africa

UN tax committee to weigh updates to model treaty, transfer pricing manual

October 20, 2020

The United Nations Committee of Experts on International Cooperation in Tax Matters kicked off its 21st session today, meeting virtually to discuss transfer pricing . . .

Multinational

Professor analyzes Australian tax authority’s transfer pricing reconstruction power as a tool to combat IP migration, focusing on Amazon case, OECD guidelines: Anthony Ting / SSRN→

October 19, 2020

Multinational

Professors propose home-country tax on MNEs that pay low effective rates: Kimberly A. Clausing, Emmanuel Saez, Gabriel Zucman / SSRN→

October 16, 2020

Digital Economy

Facebook’s cryptocurrency, Libra, presents tax policy challenges, authors note: Allison Christians & Mahwish Tazeem→

October 16, 2020

Digital Economy

G20 ministers vow to continue work on international tax rewrite

October 14, 2020

In a communique released after their October 14 virtual meeting, G20 finance ministers and central bank governors said they remain committed to achieving consensus . . .

Africa

OECD Pillar One: a closer look at the proposal’s impact and the questions that remain

October 14, 2020

Philippe Paumier of VECTOR TP, Paris, takes a closer look at the supporting impact analysis of the OECD blueprint on pillar one and considers the future of the proposal . . .

Africa

The Pillar One blueprint — the potential future of international taxation and transfer pricing

October 13, 2020

Leslie Prescott-Haar and Sophie Day at TP EQuilibrium | AustralAsia LP provide a detailed look at the report on the Pillar One blueprint, approved by the Inclusive Framework on BEPS and released by the OECD on October 12 . . .

Africa

Countries unable to agree on global tax overhaul, new blueprint reports released

October 12, 2020

An OECD-led coalition of 137 countries known as the Inclusive Framework on BEPS failed to reach agreement on a coordinated update to the international tax rules at their October plenary meeting, OECD . . .

G20

OECD Secretary-General reports on status tax policy initiatives to G20 finance ministers: OECD→

October 12, 2020

Digital Economy

OECD should reconsider formulary methods as pillar one and two do not benefit small and poor countries and are too complex, civil society group says: The BEPS Monitoring Group→

October 12, 2020

Belgium

The new Belgian government’s agreement: a symphony with tax notes

October 7, 2020

Geoffroy Galéa, Of Counsel and Head of the Tax Practice at Fieldfisher, Brussels, discusses a policy paper, agreed to September 30 by Belgium’s new government, the so-called “Vivaldi coalition,” which includes the coalition’s position on international tax matters . . .

OECD to provide update of global tax negotiation on Monday

October 7, 2020

The OECD today announced that it will provide an update of the status . . .

Africa

COVID-19 test producer Qiagen’s intercompany financing – the transfer pricing issues

October 6, 2020

Dr. Harold McClure, a New York City Economist, discusses an analysis by Vincent Kiezebrink and Jasper van Teeffelen which accuses biotech firm Qiagen of base erosion through the use of intercompany loans . . .

Multinational

NGO expresses support for UN model tax treaty clarification providing that all payments for rights to use computer programs or software are covered in royalties article: The BEPS Monitoring Group→

October 6, 2020

Americas

Pillar 2 negotiations could result massive increase in global tax and compliance costs, undermining COVID-19 recovery efforts, US advocacy group says: Peter Sepp / National Taxpayers Union→

October 5, 2020

Africa

African tax administrators release model digital services tax legislation, say global tax deal unlikely this year

October 1, 2020

The African Tax Administration Forum (ATAF), comprised of tax administrations from 38 African countries, on September 30, published sample digital . . .

Asia-Pacific

Jordan becomes 53rd country to deposit instrument of ratification for BEPS MLI: OECD→

September 30, 2020

Africa

Botswana, Eswatini, Jordan, and Namibia sign Multilateral Convention on Mutual Administrative Assistance in Tax Matters: OECD→

September 30, 2020

Multinational

Tax Inspectors Without Borders activities described in new report: OECD/UNDP→

September 30, 2020

Asia-Pacific

Vodafone wins tax dispute in international arbitration: India’s dilemma

September 29, 2020

Bijal Ajinkya, Ashish Mehta, and Krutika Chitre, of Khaitan & Co, Mumbai, discuss Telecom giant Vodafone’s win against the Republic of India in international arbitration, in a tax case involving the indirect transfer of assets, and India’s possible next steps . . .

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