The agreement represents a major change for tax competition, and many countries will be rethinking their tax policies for multinationals. If there is no agreement on changes to Pillar Two or digital services taxes, retaliatory American tariffs could be on the horizon.
8 min read
Short FormThe technical rules that were once solely the province of tax wonks in D.C. and Paris are being brought out into the public sphere.
5 min read
If a multilateral solution to remove digital services taxes (DSTs) is not agreed to, then DSTs will continue to spread and mutate with negative impacts on some of the most innovative companies in the world.
Pillar Two, the international global minimum tax agreement, has a considerable chance of failing and may ultimately allow the same problems it was designed to address.
6 min read
The Tax Cuts and Jobs Act of 2017 (TCJA) reformed the U.S. system for taxing international corporate income. Understanding the impact of TCJA’s international provisions thus far can help lawmakers consider how to approach international tax policy in the coming years.
30 min read
Simplifying international tax rules will not solve all the challenges that stand in the way of healthy cross-border investment, but eliminating unnecessary provisions would be a positive pivot relative to the trajectory of recent years. It’s high time that policymakers stopped pursuing ever more complex rules and started the hard work of simplification.
6 min read
European Union Member States are in the process of implementing the global minimum tax in line with a directive unanimously agreed to at the end of 2022.
3 min read
The Moore case could have important impacts on tax policy.
5 min read
The outcome of the digital tax debate will likely shape domestic and international taxation for decades to come. Designing these policies based on sound principles will be essential in ensuring they can withstand challenges arising in the rapidly changing economic and technological environment of the 21st century.
58 min read
The global landscape of international corporate taxation is undergoing significant transformations as jurisdictions grapple with the difficulty of defining and apportioning corporate income for the purposes of tax.
22 min read
Pillar Two, the international global minimum tax agreement, has a considerable chance of failing and may ultimately allow the same problems it was designed to address.
6 min read
What does it mean to be an American company?
4 min read
Historical evidence and recent studies have shown that retaliatory tax and trade proposals raise prices and reduce the quantity of goods and services available to U.S. businesses and consumers, resulting in lower incomes, reduced employment, and lower economic output.
5 min read
The Tax Cuts and Jobs Act of 2017 (TCJA) reformed the U.S. system for taxing international corporate income. Understanding the impact of TCJA’s international provisions thus far can help lawmakers consider how to approach international tax policy in the coming years.
30 min read
In such a determinant semester for Europe, principled tax policy can be an important tool for a more competitive European Union.
5 min read
The rules of tax competition are changing with the recent agreement on a global minimum tax and other changes to tax rules around the world, but that does not mean the contest is over.
5 min read
The EU Tax Observatory has taken an extreme view in assessing the global minimum tax. The rules were not meant to immediately reduce the stock of shifted profits or align profitability levels more closely with employment costs. The rules do change incentives for multinationals, but profits may continue to remain in low-tax jurisdictions for many years.
6 min read
If the EU is going to harmonize its tax base, it should do so in a way that increases the efficiency and competitiveness of tax policy for the EU as a whole, and not just seek out the lowest common denominator.
5 min read
The OECD recently released a trove of new documents on a draft multilateral tax treaty. The U.S. Treasury has opened a 60-day consultation period for the proposal and is requesting public review and input.
7 min read
The global minimum tax agreement known as Pillar Two is intended to curb profit shifting. However, OECD countries already have a variety of mechanisms in place that seek to prevent base erosion and profit shifting by multinational corporations.
40 min read
Pillar Two implementation is underway in many jurisdictions, and many governments are aiming to get their proposals approved before the end of 2023. However, estimating Pillar Two’s impact on government revenue is proving difficult. As a result, only a few countries have publicly presented their findings.
7 min read
Simplicity in the tax code means taxes should be easy for taxpayers to pay and easy for governments to administer and collect.
In recent years, European countries have undertaken a series of tax reforms designed to maintain tax revenue levels while protecting households and businesses from high inflation.
8 min read
On 12 September, the European Commission released a proposal called “Business in Europe: Framework for Income Taxation” (BEFIT) and two associated proposals on transfer pricing and a Head of Office tax system.
6 min read
Congress should recognize that Pillar Two has significant U.S.-specific downsides, but also that it cannot unilaterally stop Pillar Two from taking effect. Instead, it should carefully consider a policy response for the next Congress, when a variety of forces are likely to compel it to act.
7 min read
A major case pending before the U.S. Supreme Court (Moore v. United States) is calling into question provisions on large portions of the U.S. tax base which could quickly become legally uncertain, putting significant revenue at stake.
7 min read