Multinational

Digital Economy

Taxable nexus should be based on the factors of sales, employees, or property in a jurisdiction to address digital economy, professor writes: Monica Gianni / SSRN→

October 3, 2018

Featured News

Draft OECD/IGF guide addresses mining sector tax avoidance through excessive interest deductions

April 18, 2018

The OECD’s Centre for Tax Policy and the Intergovernmental Forum on Mining, Minerals, Metals and Sustainable Development (IGF) today jointly released a draft practice note addressing how governments . . .

Featured News

113 countries endorse OECD interim report on taxation of digital economy

March 15, 2018

The Inclusive Framework in BEPS, a coalition of 113 countries, has approved an interim report addressing tax challenges associated with the digital economy, Pascal Saint-Amans, director . . .

Asia-Pacific

Hong Kong, Switzerland agree to automatic exchange of information on taxes

October 13, 2017

Hong Kong and Switzerland today signed an agreement for automatic exchange of financial account information in tax matters (AEOI). The agreement would commence in 2018 and the first exchange of data between tax authorities would . . .

Multinational

OECD weighs expanding PE definition for digital presence, alternative tax on sales, Saint-Amans says: Alex M. Parker / Bloomberg BNA→

August 30, 2017

Africa

Nigeria signs MLI to tackle tax avoidance by multinational firms

August 17, 2017

Nigeria today signed the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base . . .

EU report addresses proposal for a common consolidated corporate tax base (CCCTB): EU Parliament→

May 8, 2017

Multinational

Authors analyze treaty shopping, identify key conduit countries: Maarten van ‘t Riet & Arjan Lejour / SSRN→

April 27, 2017

Africa

Paper reviews findings of 9 academics on likely impact of BEPS anti-hybrid rules on Uruguay, Colombia, Brazil, South Africa: SSRN→

March 29, 2017

See: SSRN.

Austria

Multinationals asked to critique tax dispute resolution processes in Austria, France, Germany, Italy, Liechtenstein, Luxembourg, Sweden

January 30, 2017

The OECD has today asked global businesses to assess the mutual agreement procedure (MAP) for resolving tax treaty disputes in Austria, France, Germany, Italy . . .

EU publishes CCTB, CCCTB, ATAD II directives proposing major tax reform for multinationals

October 25, 2016

Paulus Merks, Jian-Cheng Ku, and Jesse Peeters of DLA Piper, Amsterdam, discuss today’s release by the EU Commission of three tax directives, the CCTB, CCCTB, and ATAD II, which will potentially have a significant impact on multinationals operating in the European Union . . .

Multinational

Authors analyze OECD draft transfer pricing rules for intragroup financial guarantees: Vera Averyanova & Vikram Chand / Kluwer International Tax Blog→

February 15, 2019

Digital Economy

Professors say location of “sustained user relationship” should confer taxation rights in digital era: Johannes Becker, Joachim English / SSRN→

October 2, 2018

Featured News

OECD, UN, IMF, World Bank release revised “toolkit” on taxation of offshore indirect asset transfers

July 17, 2018

The IMF, OECD, UN, and World Bank Group, through a joint initiative known as the “Platform for Collaboration on Tax,” released a revised draft “toolkit” on July 16 that addresses how countries can change their laws to prevent tax-motivated offshore indirect transfers. . .

Digital Economy

G7 leaders agree to work toward resolving dispute over taxing multinational digital firms

June 12, 2018

Following their summit in Charlevoix, Quebec, Canada, held June 8–9, six of the seven G7 leaders pledged to continue to work toward reaching agreement on the taxation of digital multinationals, to collaborate to achieve fair taxation, and continue their efforts to . . .

Americas

US could defy WTO if it loses EU challenge to FDII, professors say: Reuven S. Avi-Yonah & Martin G. Vallespinos→

February 8, 2018

Featured News

OECD releases public comment letters on profit split, permanent establishment drafts concerning multinational tax

October 7, 2017

The OECD on October 6 released 44 public comment letters responding to a discussion draft providing guidance on profit splits and 48 public comments on a draft on the attribution of profits to permanent establishments. Both drafts were released June 22 and are designed to set international . . .

Swedish ruling concludes parent-subsidary directive anti-avoidance rule inapplicable to dividend distribution to Maltese parent: EY→

May 17, 2017

Featured News

OECD releases more country-by-country reporting guidance for large multinationals

April 7, 2017

Davide Anghileri of the University of Lausanne discusses OECD tax guidance, released April 6, which further clarifies the country-by-country reporting rules for large multinational groups . . .

G20

Countries lose significant revenue from multinational tax avoidance, OECD paper concludes

February 15, 2017

Multinationals, particularly the largest firms, take advantage of profit shifting to low tax rate countries, mismatches between country tax systems, and preferential tax regimes to significantly lower their tax bills, though countries that strengthen their antiavoidance laws may be able . . .

Multinational

PwC to hire 600+ GE tax professionals

January 14, 2017

In a surprising move, PwC has agreed to hire more than 600 members of GE’s tax team from around the world and provide tax services to GE on . . .

Belgium

EU Commission publishes decision concluding Belgium’s excess profits tax scheme is State aid

May 4, 2016

The EU Commission today published a non-confidential version of its decision that Belgium’s excess profits tax scheme is illegal under EU State aid rules. The Commission’s decision, first announced in a press release last . . .

Africa

Karanja to head OECD/UN Tax Inspectors Without Borders initiative

March 21, 2016

Kenyan tax official, James Karanja will lead the joint OECD/UN Tax Inspectors Without Borders (TIWB) initiative effective April 11, the OECD announced today. Karanja is assistant manager of the international tax . . .

Asia-Pacific

Singapore-Ireland tax treaty MLI amendments enter into effect

May 2, 2019

The Singapore government has announced that amendments made to the Singapore-Ireland tax treaty as a result of . . .

International Monetary Fund

IMF paper proposes criteria for assessing international tax reform proposals: International Monetary Fund→

March 12, 2019

Multinational

OECD releases corporate tax statistics analyzing revenues, statutory and effective rates, tax incentives for innovation: OECD→

January 22, 2019

Asia-Pacific

Saudi Arabia signs BEPS MLI to combat tax avoidance

September 18, 2018

The OECD today announced that Saudi Arabia has signed a multilateral tax treaty designed to allow countries to swiftly add to their existing bilateral tax treaties additional provisions . . .

Multinational

Patent boxes may not encourage innovation, academics say: Fabian Gaessler, Bronwyn H. Hall, & Dietmar Harhoff / SSRN→

August 22, 2018

Americas

OECD asks MNEs for feedback on cross-border tax dispute resolution in Argentina, Chile, Colombia, Croatia, India, Latvia, Lithuania, South Africa

July 26, 2018

The OECD is seeking feedback on multinationals’ experience with cross-border tax dispute resolution procedures in . . .

Europe

UK publishes final MLI reservations and notifications

July 17, 2018

The UK has published its final list of reservations and notifications to the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base . . .

Multinational

Paper addresses mandatory disclosure rules, effect of time lag between innovation or imitation of aggressive tax planning products and regulatory action: Kai A. Konrad/SSRN→

June 26, 2018

Americas

New OECD project aims to encourage proper use of tax treaty principal purpose test, official says

June 10, 2018

The OECD is working on a project designed to encourage tax administrations to act reasonably when interpreting and applying the principal purpose test, an official said at the 2018 OECD International Tax Conference, held . . .

International Monetary Fund

MNEs move operations when countries adopt transfer pricing regulations, IMF paper says: Ruud A. de Mooij & Li Liu / IMF→

March 27, 2018

Featured News

OECD releases cross-border VAT implementation guidance

October 24, 2017

The OECD today released guidance designed to assist policy makers in their effort to evaluate and develop the legal and administrative framework for collecting VAT on cross-border sales. The . . .

Featured News

Progress needed on international tax rules for digital companies, OECD’s Saint-Amans says

September 14, 2017

Countries will continue to advance unilateral measures to tax digital businesses unless there is some sign that international consensus can be reached on appropriately taxing these firms, an OECD official warned Wednesday. Speaking during . . .

Africa

BRICS countries agree to coordinate response to G20 international tax work

July 31, 2017

Tax authorities of the five BRICS nations – Brazil, Russia, India, China and South Africa – agreed to enhance their cooperation on international tax matters during the annual meeting of the heads of the BRICS revenue administrations, held . . .

Multinational

MNEs urge UN to not add tax avoidance to list of sustainable development goals: Tom Murphy / Humanosphere→

July 3, 2017

Featured News

68 nations sign multilateral treaty on tax avoidance, dispute resolution

June 7, 2017

Officials representing 68 countries and jurisdictions on June 7 signed a multilateral instrument to amend their existing tax treaties, adding provisions designed to curtail multinational tax avoidance and strengthen tax dispute resolution . . .

Africa

Djibouti joins ‘Inclusive Framework on BEPS’ to fight tax avoidance

May 31, 2017

The OECD today announced that Djibouti has pledged to work alongside other nations on the continuing the work of the OECD/G20 base erosion profit . . .

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

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