Multinational

Africa

90+ countries’ laws comply with country-by-country reporting standard, OECD report concludes

September 25, 2020

More than 90 countries have introduced laws requiring the collection of country-by-country reports on multinational groups that . . .

Africa

The OECD’s pillar one blueprint – is pharma in or . . . in?

September 23, 2020

Philippe Paumier of VECTOR TP, Paris, discusses the OECD draft pillar one blueprint’s implications for pharmaceutical companies . . .

Albania

Albania, Bosnia and Herzegovina, Costa Rica join BEPS MLI, France adds more treaties

September 23, 2020

Albania, Bosnia and Herzegovina, and Costa Rica have deposited their instruments of ratification . . .

Africa

Revised (Sept 16) draft pillar one and two digital tax blueprints now available

September 23, 2020

The international tax community needs to again thank McGill Professor Allison Christians for getting ahold of leaked copies of the latest versions of the pillar one and pillar two digital tax . . .

Africa

EU may address public country-by-country reporting this year, German minister says

September 21, 2020

The EU may soon take up the issue of whether country-by-country reports detailing the tax affairs of large multinationals should be made public, German Federal Minister of Finance Olaf Scholz said today . . .

Africa

Customs valuation and intercompany royalties: the Curtis Balkan case

September 21, 2020

Economist Dr. Harold McClure, New York City, discusses transfer pricing issues associated with intercompany royalties . . .

Americas

US professors advocate increasing corporate tax rates to tax “economic rents”, the supersized returns that accrue to capital owners when companies enjoy market power or other non-reproducible advantages: Edward G. Fox & Zachary D. Liscow / SSRN→

September 18, 2020

Asia-Pacific

Tax Inspectors Without Borders, a joint OECD/UNDP initiative, has launched its first program in Kazakhstan: TIWB / Twitter→

September 17, 2020

Multinational

Dutch multinational Philips to publish its country-by-country reporting data, Oxfam tax policy expert notes: Johan Bernardo Langerock / Twitter→

September 17, 2020

Americas

The transfer pricing implications of Armani’s US advertising payments

September 17, 2020

New York City economist Dr. Harold McClure discusses a difficult transfer pricing issue often faced by multinational apparel and shoe manufacturers, namely, how to treat locally incurred advertising expenses where the foreign parent formally owns the trademarks . . .

Digital Economy

EU will propose its own digital tax plan if global agreements “fall short of a fair tax system that provides long-term sustainable revenues,” President von der Leyen says: European Commission→

September 16, 2020

Digital Economy

EU to propose digital tax by June 2021 if OECD process fails, official says: Valdis Dombrovskis / EU Commission→

September 14, 2020

Americas

Pillar 2 is a big threat to Bermuda re/insurers, trade group rep says: Intelligent Insurer→

September 14, 2020

Multinational

Not all forms of legal tax planning are socially legitimate; corporations should pay their fair share, develop tax codes of conduct, provide tax transparency, researcher argues: Ave-Geidi Jallai / SSRN→

September 14, 2020

G20

G20 should encourage better design of tax expenditures that have implications for international trade, authors say: Agustín Redonda, Facundo Calvo, Gilles Carbonnier, Irma Mosquera Valderrama, Rahul Mehrotra, Robert Koopman / Think20→

September 11, 2020

International Monetary Fund

MNE tax system is failing because it is incompatible with increasing global business integration, digitalization, services and intangibles trade, IMF author says: Shafik Hebous / International Monetary Fund→

September 11, 2020

Americas

France says US blocking global digital tax talks: Reuters→

September 10, 2020

Africa

UN model treaty proposal would impose withholding tax on software payments

September 9, 2020

Jian-Cheng Ku and Xander Stubenrouch of DLA Piper Nederland N.V., Amsterdam, discuss a September 1 discussion draft under consideration by the UN Committee of Experts on International Cooperation in Tax Matters which proposes an amendment the UN model tax convention to include software payments in the definition of royalties . . .

Multinational

PCT extends deadline for comments on tax treaty negotiation toolkit to September 24: Platform for Collaboration on Tax→

September 9, 2020

Americas

OECD publishes report on tax policy reforms enacted both before and after COVID-19 in 37 OECD member countries plus Argentina, China, Indonesia, South Africa: OECD→

September 4, 2020

Africa

Leaked OECD draft pillar one and pillar two digital tax blueprints available

September 3, 2020

McGill University professor, Allison Christians, today published the full text of the OECD pillar one and pillar two blueprints . . .

OECD publishes tax information exchange reviews for Anguilla, Chile, China, Gibraltar, Greece, Korea, Malta, Papua New Guinea, Uruguay: OECD→

September 3, 2020

Africa

Taxing somewhere, no matter where: what is the GLoBE proposal really about

September 2, 2020

Dr. Leopoldo Parada a lecturer at the University of Leeds School of Law, UK, makes the case for rejecting the global anti-base erosion proposal, also known as “GloBE,” introduced into the international tax debate by the OECD . . .

Americas

Economist calls on UN development agency to oppose EU tax blacklisting of Barbados and other small states, calling the action “blatantly discriminatory” policy: Marlon Madden / Barbados Today→

September 1, 2020

Digital Economy

UN subcommittee advances model tax treaty article on automated digital services

August 31, 2020

A UN Committee of Experts on International Cooperation in Tax Matters subcommittee has concluded that the drafting group developing proposed UN model tax treaty Article 12B, addressing the taxation of automated. . .

Multinational

Profs suggest new global rules requiring MNEs to pay more tax in their home country to make up for low effective tax rates paid in other countries: Kimberly A. Clausing, Emmanuel Saez, Gabriel Zucman / SSRN→

August 26, 2020

Americas

Covid-19 has accelerated foreign governments’ need to collect tax revenue from digital giants and the risk of US-led trade war: Vijay Govindarajan, Anup Srivastava , Hussein Warsame, & Luminita Enache / Harvard Business Review→

August 25, 2020

Africa

The revised operating lease accounting standards: what are the implications for transfer pricing?

August 24, 2020

Dr. Harold McClure, a New York City economist, discusses how recently revised accounting standards for entities with leased assets impact the financial metrics often used in transfer pricing . . .

Africa

Egypt parliament approves MLI: Egypt Today→

August 21, 2020

Airbnb backs OECD approach to digital services tax: Reuters→

August 13, 2020

Asia-Pacific

India issues comprehensive guidance on cross-border tax dispute resolution

August 11, 2020

Ritu Shaktawat, Partner, and Raghav Kumar Bajaj, Principal Associate, at Khaitan & Co, Mumbai, discuss India guidance, released August 7, on the procedure for resolving cross-border tax disputes under the mutual agreement procedure (MAP) set out in India’s tax treaties with other nations . . .

Multinational

OECD working paper concludes that, rather than being regressive, VAT is roughly proportional or slightly progressive in most of the 27 OECD countries examined: OECD→

August 11, 2020

Americas

Public input sought on Brazil, OECD transfer pricing harmonization

August 7, 2020

Francisco Moreira, a Partner, Bocater Advogados, São Paulo, Brazil, discusses a July 30 request made by the OECD and Brazil’s tax authority, Receita Federal, for the public to contribute to research regarding harmonizing the Brazilian transfer pricing legislation with the OECD transfer pricing guidelines . . .

Americas

UN committee proposes new model treaty provision altering taxation of automated digital services

August 6, 2020

The UN Committee of Experts on International Cooperation in Tax Matters today released a proposed optional UN model tax treaty article that would grant additional taxing rights to countries where an automated digital services provider’s customers . . .

Africa

Global Forum publishes toolkit to help countries join global treaty providing for cooperation in tax matters: Global Forum on Transparency and Exchange of Information for Tax Purposes→

July 31, 2020

Multinational

OECD again updates listing of tax policy measures enacted in response to COVID-19: Twitter / OECDtax→

July 31, 2020

International Monetary Fund

PCT webinar addressing new Toolkit on Taxation of Indirect Transfers features presentations by OECD, IMF officials: Platform for Collaboration on Tax→

July 30, 2020

Africa

OECD reports assess cross-border tax dispute resolution in Andorra, Bahamas, Bermuda, BVI, Cayman Islands, Faroe Islands, Macau, Morocco, Tunisia

July 30, 2020

The OECD on July 27 published reports approved by a group of 135+ countries known as the “Inclusive Framework on BEPS” that assess . . .

Africa

New IGF, ATAF initiative seeks to improve mining sector taxation: Intergovernmental Forum on Mining, Minerals, and Sustainable Development→

July 30, 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