International
-
May 17, 2024
Italian Financial Police Uncover €1B Tax Credit Scam
The Italian Financial Police placed more than 300 people under investigation after uncovering a scheme to collect more than €1 billion ($1.09 billion) in tax credits designed to promote construction and energy matters, authorities said.
-
May 17, 2024
Transfer Pricing Deal Needed For Pillar 1, OECD Official Says
It's crucial for countries to agree on transfer pricing policies under an international profit reallocation agreement known as Pillar One as they work toward their end-of-June deadline to sign a related multilateral treaty, an OECD official said Friday.
-
May 17, 2024
New Dutch Gov't Outlines Range Of Tax Measures
The incoming Dutch government has outlined numerous tax measures affecting companies and individuals in its preliminary coalition agreement, a government document showed.
-
May 17, 2024
UK, Peru Agree To Double-Tax Treaty
The U.K. and Peru reached a deal on a treaty to prevent double taxation after several years of discussion, the countries said Friday.
-
May 17, 2024
Taxation With Representation: Wachtell Lipton, Freshfields
In this week's Taxation with Representation, Nippon Life acquires Corebridge Financial, Crescent Energy buys SilverBow Resources and Uber purchases Foodpanda.
-
May 16, 2024
Pillar 1 Faces Hard June Deadline, Ex-Treasury Official Says
An international agreement to reallocate certain corporate profits, known as Pillar One, will likely stall if countries miss their deadline to sign a multilateral treaty by the end of June, a former U.S. Treasury official said Thursday.
-
May 16, 2024
Australian Lawmakers OK Tougher Corporate Promoter Rules
Australian lawmakers agreed Thursday to raise maximum penalties on corporations that promote tax avoidance schemes and to introduce a cap on deductions under its petroleum resource rent tax despite concerns from some members, according to documents published by Parliament.
-
May 16, 2024
P&G Exec Says FDII Uncertainty May Sway Cos.' IP Decisions
The 2017 tax overhaul's measure for foreign-derived intangible income, a regime that gives tax breaks for domestically held intellectual property, faces uncertainty that could be one factor in keeping some companies from repatriating IP, a tax executive for Procter & Gamble said Thursday.
-
May 16, 2024
Eaton Must Give Up Personnel Docs In Transfer Pricing Probe
Eaton must comply with an Internal Revenue Service summons for the personnel records of its foreign employees in the government's transfer pricing investigation of the multinational power management company, an Ohio federal judge ruled Thursday.
-
May 16, 2024
African Tax Admins Promote Use Of Voluntary Disclosures
Voluntary disclosure programs have been very effective when countries launch them in anticipation of complying with an international standard on automatic exchanges of financial account information, the African Tax Administration Forum said Thursday in guidance on the programs.
-
May 16, 2024
Kenya Considering Global Minimum Tax, DST Replacement
Kenya is considering legislation that would implement the Organization for Economic Cooperation and Development's corporate global minimum tax as well as repeal and replace the country's digital services tax.
-
May 16, 2024
Germany's 2024 Tax Revenue Estimate Drops By €14B
Germany's 2024 tax revenue estimate decreased by roughly €14 billion ($15.2 billion) to €950.3 billion from the estimate made last fall, which its finance ministry said Thursday was due to slower-than-expected economic recovery.
-
May 16, 2024
Suspected Ringleader Of €2M Cosmetics VAT Fraud Arrested
The suspected ringleader of a value-added tax fraud scheme at a cosmetics company that caused more than €2 million ($2.2 million) in estimated losses has been arrested by Italian police, the European Public Prosecutor's Office said Thursday.
-
May 16, 2024
EU Tax On Excess Corp Profits Could Yield €107B, Study Says
A European Union tax on excessive corporate profits could yield about €107 billion ($116 billion) to partly finance the common EU budget or other urgent investments, leftists in the European Parliament said Thursday.
-
May 16, 2024
Treasury Provides Extra Relief For Bonus Energy Tax Credits
The U.S. Treasury Department provided additional safe harbors Thursday that clean energy project developers can use to qualify for bonus tax credits for domestically sourcing their steel and aluminum parts in response to the Biden administration's new trade restrictions on solar products from China.
-
May 16, 2024
Lithuania PM Wants Frozen Russian Assets To Help Ukraine
Lithuania's prime minister said Thursday that Russia's frozen assets should be used to help Ukraine fight off aggression from its larger neighbor, saying that a recent European decision to use profits from frozen assets should be only a first step.
-
May 15, 2024
Russian Gas Ex-CFO Can't Nix $44M FBAR Suit, Judge Rules
The former chief financial officer of a Russian gas company who was sentenced to seven years in prison for hiding money in Swiss banks can't escape the government's civil suit seeking nearly $44 million in reporting penalties, a Florida federal judge ruled Wednesday.
-
May 15, 2024
EU Court Upholds Ruling Against Spanish Ship Tax Scheme
The European Union's General Court upheld Wednesday a European Commission ruling that a Spanish tax scheme for ships constructed in the nation's domestic shipyards was incompatible with the EU's internal market.
-
May 15, 2024
Schulte Roth Adds Ex-Kleinberg Kaplan Partner To Tax Group
Schulte Roth & Zabel LLP added a former Kleinberg Kaplan Wolff & Cohen PC partner with a focus on private investment funds to its tax group in New York.
-
May 15, 2024
3 Key Takeaways From Floated Foreign Trust Reporting Rules
Proposed rules for reporting transactions with foreign trusts recently issued by the U.S. Treasury Department provide breathing room on disclosure requirements for certain offshore retirement accounts, but leave open some questions about classification. Here, Law360 breaks down three sections of the proposed foreign trust reporting regulations.
-
May 15, 2024
South African Tax Official Says Data Swaps Too Limited
South Africa's requests to exchange information on taxpayers with authorities around the world are often denied for criminal investigations of tax crimes, while automatic exchanges sometimes lack the full identifying information of taxpayers, the commissioner of the country's tax agency said Wednesday.
-
May 15, 2024
Taxpayers Let Down By HMRC Digital Service, Says Watchdog
HM Revenue and Customs has let down taxpayers by failing to deliver better online services, according to a report published on Wednesday by the public spending watchdog.
-
May 15, 2024
Swiss Seek Feedback On Crypto Information Exchange
Switzerland's executive body, the Federal Council, is seeking feedback from the public on its plan to adopt two Organization for Economic Cooperation and Development standards that will update the country's automatic exchanges of information to account for crypto-assets, it said Wednesday.
-
May 15, 2024
11 Arrested In €25M Italian VAT Fraud Case
Italian police arrested 11 suspects in a value-added tax fraud ring involving electronic products that resulted in losses of over €25 million ($27.2 million), the European Public Prosecutor's Office said Wednesday.
-
May 15, 2024
Gentiloni Warns EU States Not To Be Too Harsh With Budgets
European Union tax commissioner Paolo Gentiloni warned EU countries Wednesday not to be too aggressive with budget cuts, even as some may have to take a more restrictive fiscal stance this year and next than had been planned.
Expert Analysis
-
IRS Should Level The Field For R&D Tax Credits
A recent increase in denials of research and development tax credits to small businesses in the architectural, engineering and construction community shows the Internal Revenue Service should issue new guidance to ensure a fair playing field and an opportunity to continue innovating in the U.S., says Julio Gonzalez at Engineered Tax Services.
-
Applying OECD Guidance On COVID-19 Transfer Pricing
In light of the recently released Organization for Economic Cooperation and Development's guidance on the transfer pricing implications of the pandemic, taxpayers should be prepared to explain and defend their transfer pricing decisions for fiscal year 2020 for contemporaneous documentation and in future tax audits, say Susan Fickling and TJ Michaelson at Duff & Phelps.
-
Mitigate Key FCPA Risks With Tailor-Made Compliance
Multinational companies should take a pragmatic approach to Foreign Corrupt Practices Act compliance by being aware of key risk areas — such as inappropriate gift-giving, liability for third-party actions, and countries with recurring corruption issues — and implementing custom-designed procedures that evolve with their operations, says Howard Weissman at Miller Canfield.
-
Tax Takeaways From India's Proposed Budget
Consultants at Deloitte discuss the tax implications of India's latest budget proposals, including the potential benefits for foreign portfolio investors and offshore funds migrating to India's new international financial services center, and the possible rise of M&A costs.
-
A Tough Road Ahead for Democrats' Ambitious Policy Agenda
While Democrats in Congress are well on their way to enacting an initial COVID-19 relief bill, they will face challenges when pivoting to President Joe Biden's Build Back Better goals for job creation and economic revitalization, say Russell Sullivan and Radha Mohan at Brownstein Hyatt.
-
Coca-Cola Tax Ruling Offers 5 Lessons For Multinationals
The U.S. Tax Court's decision that Coca-Cola owes more than $3.3 billion in taxes is instructive on important transfer pricing concepts, including those regarding intercompany agreements, the arm's-length standard and tax certainty, says Justin Radziewicz at Duff & Phelps.
-
Start Preparing For Germany's Corporate Sanctions Act
Germany’s soon-to-be-adopted Corporate Sanctions Act carries a presumption of mandatory prosecution but also a defense in cases where reasonable precautions fail to prevent nonmanagers from committing crimes, so companies should start putting such compliance programs into place now, say attorneys at Arnold & Porter.
-
Analyzing Illegality Defense Trend In Investor-State Arbitration
Cairn Energy v. India, a recent Permanent Court of Arbitration case, highlights the growing trend of states alleging illegal investor conduct to challenge tribunal jurisdiction or investor claim admissibility, say Caline Mouawad at Chaffetz Lindsey and Jessica Beess und Chrostin at Covington.
-
Small Biz Should Self-Advocate For Tax Relief Under Biden
Small and medium-sized businesses have significant potential for achieving regulatory relief from the U.S. Department of the Treasury and other federal agencies during the Biden administration, but to do so they must define their priorities, leverage two federal statutes that require the Treasury to protect them and make their voices heard through communal e-advocacy, says Monte Silver at Silver & Co.
-
Consider Mutual Agreement Procedures For Double Tax Relief
Taxpayers wary of using mutual agreement procedures for double taxation relief should revisit the process, which is more straightforward than many believe, lest they miss out on tax savings, says Monique van Herksen of Simmons & Simmons.
-
A Road Map For US Involvement In Europe's Cum-Ex Probe
The dividend arbitrage trading strategy known as cum-ex continues to face regulatory scrutiny in Europe, and stateside regulators may soon follow suit with the U.S. Securities and Exchange Commission’s recent American depositary receipt probe as a guide for enforcement, says Joshua Ray at Rahman Ravelli.
-
Congress Should Make TCJA Income Definition Permanent
Congress should not allow the Tax Cuts and Jobs Act's definition of adjusted taxable income, which includes depreciation and amortization, to expire in 2022 because it would discourage debt-free investment, running counter to the law's intent, says George Callas at Steptoe & Johnson.
-
OECD Delays Are Imperiling Digital Tax Deal
As the Organization for Economic Cooperation and Development continues to push back its deadline for a digital tax overhaul, countries are beginning to pursue unilateral solutions and the negotiations are turning political, decreasing the likelihood of an agreement, says Joyce Beebe at Rice University.