Multinational
Mexico proposes new transfer pricing rules of the game
Jesús Aldrin Rojas M., QCG Transfer Pricing Practice, discusses the Mexican government’s September 8 decree that would modify the transfer pricing regime to enhance its effectiveness as a tax collection and audit instrument for the tax authorities, providing new and aggressive rules of the game for . . .
Global minimum tax negotiations focus on carve-outs, EU consensus, closing deal
Negotiators are seeking to achieve final consensus on the details of the global minimum tax deal, according to September 29 comments from European Commission official Benjamin Angel, with talks centering on the terms for carve-outs and other technical aspects that might bring into the fold remaining . . .
US Democrats’ hopes of overhauling TCJA’s foreign taxes stemmed by global pressure
Alex M. Parker, Capitol Counsel LLC, discusses why the most recent version of the Democrats’ plan for overhauling the US tax code – approved by the House Ways and Means committee on September 15 – suggests the party may be backing down on its promise to repeal a key part of the Tax Cuts and Jobs Act’s . . .
OECD’s GloBE rules: Blending in with jurisdictional blending
Noopur Trivedi and Jitesh Golani, international tax researchers, discuss how – out of the multiple design elements of the global minimum tax in the OECD/G20 July 1 statement – the adoption of “jurisdictional blending” for computation of effective tax rate, and consequent top-up tax, is one of the most pivotal . . .
Belgian court rules against retroactive application of transfer pricing guidelines
Moïse Gnakouri, Catholic University of Louvain, discusses a June 8 decision from Belgium’s Court of Appeal of Ghent in a transfer pricing dispute between the Belgian tax authorities and a taxpayer in a case involving the application of a concept introduced in OECD transfer pricing guidelines in a tax year prior to . . .
Groups urge FASB to prioritize public country-by-country tax reporting
The US Financial Accounting Standards Board should adopt in its standard-setting agenda a requirement for companies to report information in the notes to their financial statements on the disaggregation of country-by-country income tax, according to a September 22 letter signed by 63 organizations that . . .
India intercompany financing: debt versus equity and the pricing of intercompany loans
New York City Economist Dr. J. Harold McClure discusses the Mumbai Income Tax Appellate Tribunal’s August 20 ruling against the Indian tax authority in Bennett Coleman & Co Ltd (As successor to Times Infotainment Media Limited) v. Deputy Commissioner of Income Tax, and analyzes the two questions . . .
Togo becomes latest country to endorse global tax reforms
The West African nation of Togo became the 140th country to join the OECD/G20 Inclusive Framework on base erosion and profit shifting (BEPS) and the 134th Inclusive Framework member to endorse the two-pillar international tax reform statement released earlier this summer, according to an August 31 . . .