Multinational

Austria

EU’s path forward on global minimum tax is under debate

January 18, 2022

EU member states are at odds on various issues related to the directive to implement within the EU the global minimum tax portion of the OECD agreement, with several members expressing concerns about key aspects in a January 17 Economic and Financial Affairs Council . . .

Asia-Pacific

Taiwan highlights changes in new tax treaty protocol with UK

January 18, 2022

Taiwan’s Ministry of Finance on January 18 explained the changes in the new amending protocol to the UK-Taiwan tax treaty, which took effect on January 1 after entering into force on . . .

Americas

Poland transfer pricing laws under review to strengthen system against tax evasive behavior

January 14, 2022

Dr. Monika Laskowska, Warsaw School of Economics, discusses the Polish Ministry of Finance’s participation since November in a project coordinated by the European Commission to reform Polish transfer pricing regulations; the project is planned to . . .

Americas

Switzerland will implement global minimum tax by constitutional amendment

January 13, 2022

The Swiss Federal Council on January 12 decided that it will implement the 15% global minimum tax agreed by the OECD Inclusive Framework through a constitutional amendment with an aim to ensure the measure comes into force as of January 1, 2024; the approach is intended to . . .

Africa

Swiss international tax update addresses OECD deal, treaties, MAP

January 12, 2022

Switzerland’s State Secretariat for International Financial Matters on January 10 issued a report on various ongoing tax projects, including the country’s take on the OECD deal, as well as the status of tax treaty negotiations, tax information exchange, mutual agreement procedure (MAP), and recent . . .

Americas

Barbados country-by-country reporting tax law takes effect

January 12, 2022

Barbados tax legislation enacting country-by-country reporting came into operation on December 31, 2021, following publication in the Official Gazette on . . .

Accounting

UK sets out approach to global minimum tax implementation

January 11, 2022

The UK government on January 11 opened a consultation on how it plans to implement and administer within the UK the OECD model rules on the internationally agreed 15% global minimum tax; the consultation also considers the introduction of a UK domestic minimum tax, as well as . . .

Africa

EU tax transparency directive: When turkeys vote for Christmas

January 10, 2022

Cédric Maheo, CWA Morocco, discusses how the EU directive on public country-by-country reporting for large multinationals, published in the Official Journal of the European Union on December 1, will give tax authorities in the developing world new data on multinationals operating in . . .

Accounting

OECD’s ‘complex’ minimum tax rules have ‘major policy issues,’ BIAC says

January 7, 2022

In a January 6 letter to the OECD, business advisory group Business at OECD (BIAC) criticizes “significant policy inconsistencies” in the OECD’s global minimum tax model rules that it considers “potentially fatal” to their operation; moreover, it contends efforts must be made to . . .

Europe

Finnish transfer pricing adjustment provision amendments are now in force

January 5, 2022

Marianna Santamala, Bird & Bird Attorneys Ltd, discusses the new amendments to the Finnish transfer pricing adjustment clause included in section 31 of the Finnish Assessment Procedure Act, which came into effect on January 1, 2022, and apply to tax years beginning on . . .

Europe

Dutch government plans amendments to CFC tax and transfer pricing rules

January 4, 2022

Robert Jean Kloprogge and Olivier Elsenburg, Simmons & Simmons LLP, discuss the prospect Dutch coalition government’s December 15 publication of its 2021–2025 agreement, including a plan to adopt recommendations regarding the Dutch controlled foreign company (CFC) rules from . . .

Europe

Malta consults on draft transfer pricing rules, APA program

December 29, 2021

The Maltese government on December 20 opened a consultation seeking feedback on draft transfer pricing rules with the intention of using the feedback to craft final transfer pricing rules to be published in late 2022 and then apply the rules to tax years beginning in . . .

Carbon Tax

EU looks to pull revenue from share of OECD tax deal, environmental measures

December 23, 2021

The European Commission on December 22 proposed three “own resources” for the EU budget, including taking a share of the taxing rights to be reallocated to EU member states under Pillar One of the OECD Inclusive Framework tax deal reached in October; the two other proposed . . .

Cyprus

EU directive sets out approach to global minimum tax, adds domestic application

December 22, 2021

The European Commission on December 22 released its proposed directive to implement within the EU the global minimum tax under Pillar 2 of the OECD agreement reached between 137 countries in October; the directive largely tracks the OECD agreement, while adding . . .

Americas

Pandora papers’ two lessons for transforming tax and financial laws

December 22, 2021

Leopoldo Parada, University of Leeds School of Law, discusses the lessons to be learned from the so-called “pandora papers” since their release by the International Consortium of Investigative Journalists (ICIJ) in October, such as the implications for the structuring of tax and financial laws going forward . . .

OECD plans four consultations on tax matters under two-pillar deal

December 21, 2021

The OECD announced on December 21 that it will seek stakeholder input on four elements of the October 8 international tax agreement; two of the consultations will address components of the Pillar 1 profit allocation rules, and the other two will address . . .

GloBE model rules: a peek into key provisions

December 20, 2021

International tax researchers Noopur Trivedi and Jitesh Golani discuss key highlights of the OECD’s much-awaited global anti-base erosion (GloBE) model rules, released on December 20, along with a commitment by the OECD to finalize the commentary and safe harbors in . . .

Americas

US tax bill stumbles as OECD rolls out global minimum tax rules

December 20, 2021

The path toward US implementation of the internationally agreed global minimum tax hit a roadblock on December 19, as a key US Senator announced he will not support the President’s bill that would adopt the tax changes; the news came just one day before the OECD’s release of . . .

Americas

ATO prevails in Singapore Telecom Australia intercompany financing litigation

December 20, 2021

New York City Economist Dr. J. Harold McClure analyzes Australia’s Federal Court of Appeals ruling on December 17 in favor of the Australian Tax Office in Singapore Telecom Australia Investments Pty Ltd v. Commissioner of Taxation – a transfer pricing case involving intercompany interest payments in . . .

Americas

Canada’s Trudeau outlines corporate and international tax priorities in mandate letter

December 17, 2021

Canadian Prime Minister Justin Trudeau includes various high-level tax policy objectives — such as measures targeting bank income and tax avoidance, as well as research and development (R&D) amendments — in a December 16 mandate letter to . . .

Americas

Canada advances digital services tax bill despite OECD pact, US objections

December 15, 2021

Canada introduced draft legislation on December 14 to implement its planned digital services tax – with a built-in delay and contingency deferring to implementation of the OECD multilateral agreement; however, if the OECD agreement under Pillar 1 is not timely implemented . . .

Africa

Kenya issues draft tax regulations on common reporting standard

December 14, 2021

The Kenyan government on December 14 published common reporting standard draft regulations under the Tax Procedures Act relating to the exchange of information in tax matters . . .

Asia-Pacific

OECD review of tax ruling exchange standard finds 36 countries could improve

December 14, 2021

Out of 131 countries the OECD reviewed in a 2020 peer review report released on December 14, 95 received no flags for improvement with respect to implementing the OECD minimum standard on exchange of information on tax rulings; however, 36 countries fell short, including . . .

Americas

Panama adapts laws on exchange of information for tax purposes to international standards

December 14, 2021

Lilia Isabel Lee, BDO Panama, discusses Panama’s November 11 approval of Law 254, amending legislation on international tax transparency and adapting the exchange of information for tax purposes to international . . .

Africa

OECD updates and expands transfer pricing country profiles

December 13, 2021

The OECD today released updated transfer pricing country profiles for 21 countries, including three countries for which it has not previously published profiles: Albania, Kenya, and . . .

Accounting

US Senate draft of budget bill tweaks corporate tax provisions

December 13, 2021

US Senate Finance Committee Chairman Ron Wyden (D-Ore.) on December 11 unveiled his version of the House’s approved budget bill for consideration in the Senate, revising some corporate tax provisions adopted in the House version, including the corporate minimum tax and . . .

Belgium

Belgium and France sign new tax treaty

December 13, 2021

Moïse Gnakouri, Catholic University of Louvain, discusses the new tax treaty Belgium and France signed on November 9, which complies with new international standards, and includes several changes, including the taxation of capital gains on the sale of shares of companies with assets consisting . . .

Accounting

Seychelles to amend business tax rates, expand transfer pricing capacity

December 9, 2021

The government of Seychelles plans to reduce its business tax rates beginning in January 2022, according to the national budget delivered November 12, and is working on other business and international tax reforms, including expanding transfer pricing . . .

Multinational

Corporate tax rates dropped in 17 countries in 2021 (including Chile, Tunisia, and France) and increased in just three (Argentina, Bangladesh, Gibraltar), continuing 40-year global downward trend in rates: Sean Bray / Tax Foundation→

December 9, 2021

Americas

OECD countries’ tax revenues fell in 2020, but less than their GDPs

December 6, 2021

The ratio of tax revenues to GDP in OECD countries rose slightly in 2020 amid the Covid-19 pandemic, as nominal tax revenues generally fell but did so at a lower rate than countries’ GDPs, according to the OECD’s 2021 annual revenue statistics released December 6; corporate income tax revenues . . .

Carbon Tax

EU’s ‘number one priority’ in tax is implementing OECD deal, Gentiloni says

December 1, 2021

Making the recent OECD Inclusive Framework agreement operational “is now crucial,” European Commissioner for Economy Paolo Gentiloni said in November 30 remarks to the European Parliament’s subcommittee on tax matters; however, it’s not the only ambitious tax initiative in the . . .

Europe

Dutch committee presents report on conduit companies and associated tax policy options

December 1, 2021

Jian-Cheng Ku, Gabriël van Gelder and Rhys Bane, DLA Piper Nederland N.V., discuss a Dutch government committee’s November 22 findings on the presence of conduit companies in the Netherlands and what tax and non-tax measures should be taken against . . .

Europe

UK updates slew of tax initiatives, including R&D, transfer pricing, MDR

November 30, 2021

The UK government on November 30, in a planned “Tax Administration and Maintenance Day,” outlined updates to numerous tax policy plans, including measures relating to research and development (R&D) tax reliefs, transfer pricing documentation, mandatory disclosure rules (MDR) . . .

Multinational

Global minimum tax’s potential to put a floor on tax competition hinges on technical issue of how substance-based carve-out is incorporated into ‘effective tax rate’ definition: Michael P. Devereux / Centre for Business Taxation→

November 29, 2021

Americas

Tax dispute resolution via mutual agreement procedure works, mostly, but is still slow

November 23, 2021

Around 75% of mutual agreement procedure (MAP) cases concluded worldwide in 2020 – both for transfer pricing and other tax cases – resulted in full resolution of the issue, according to the OECD’s 2020 MAP statistics released November 22, with only . . .

Asia-Pacific

Turkey and US agree on phase-out of digital tax

November 23, 2021

The US Treasury announced on November 22 that it has reached an agreement with the Turkish government on Turkey’s transition from its digital services tax to the new taxing rules under the . . .

Europe

Swiss federal act on implementation of international tax agreements: ready for January 2022

November 23, 2021

Francesca Amaddeo, Tax Law Competence Centre (SUPSI), discusses the Swiss Federal Council’s November 10 introduction of the federal act on the implementation of international tax agreements (ITAIA), applicable from 1 January 2022, that aims to update . . .

Europe

EU tax competition driven by R&D and other incentives, not just rates

November 22, 2021

Tax incentives for research and development (R&D) have narrowed corporate tax bases in EU countries and could be considered “a novel corporate tax competition driver,” according to a November 22 EU Tax Observatory report on new forms of . . .

Americas

US corporate and global minimum tax measures clear House, debate moves to Senate

November 19, 2021

The US House of Representatives today approved a modified version of President Biden’s Build Back Better bill – including corporate and international tax changes – following protracted debates on the revenue and economic impacts of the provisions; the Senate will take up the bill sometime after . . .

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

Ciro César Soriano de Oliveira on Danish High Court rules on beneficial ownership of dividends for tax purposes: “Dear Ms. Susi, This article is very clarifying. I wonder whether Danish Supreme Court has already granted its decision referred…” 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