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Taxation of Multinational Businesses

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CCCTB vs. BEFIT: EU Corporate Tax Base: Details & Analysis

CCCTB vs. BEFIT: How Have the Proposals Changed?

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

International Tax Competitiveness Index 2023

While there are many factors that affect a country’s economic performance, taxes play an important role. A well-structured tax code is easy for taxpayers to comply with and can promote economic development while raising sufficient revenue for a government’s priorities.

88 min read
Pillar One US Treasury Consultation on OECD proposal for public review input and comments

Five Takeaways from the New Pillar One Documents

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
Anti-Avoidance Policies in a Pillar Two World including CFC rules and Base erosion and Profit Shifting Pillar Two policies

Anti-Avoidance Policies in a Pillar Two World

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
OECD global tax deal Pillar Two revenue estimate by country of annual and average corporate tax revenue

Select Country-Level Revenue Estimates for Pillar Two

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
It Pays to Keep It Simple including for Tax Compliance and Tax Revenue in the form of Tax Simplicity

It Pays to Keep It Simple

Simplicity in the tax code means taxes should be easy for taxpayers to pay and easy for governments to administer and collect.

EU BEFIT proposal for Business in Europe Framework for Income Taxation

BEFIT: One-Stop-Shop or One-More-Stop?

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
US Pillar Two responses should include a policy response from Congress on the OECD global tax deal's global minimum tax

How the U.S. Can Piece Together a Solution for Pillar Two

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
Risks to the U.S. Tax Base from Pillar Two

Risks to the U.S. Tax Base from Pillar Two

A growing international tax agreement known as Pillar Two presents two new threats to the U.S. tax base: potential lost revenue and limitations on Congress’s ability to set its own tax policy.

39 min read
UN tax cooperation efforts Tax Foundation response on cross border trade and investment United Nations general assembly

Global Tax Tug of War: Comparing the UN and OECD Approaches

The United Nations (UN) is preparing to flex its muscles on international tax policy. Several developing countries say the OECD’s approach favors richer countries at their expense, and the UN hopes to fix this.

5 min read
Canada digital services tax Canada digital tax proposal health care premiums and Canada marginal tax rates and Canada upward mobility

Another Digital Services Tax in Sight

Canada is planning to join the club of countries that, in the past 3 years, introduced a digital services tax (DST) despite U.S. opposition and concerns expressed by Canadian businesses.

4 min read

Weeding the Garden of International Tax

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
Carbon Border Adjustment Mechanism EU CBAM carbon price carbon tariffs US global minimum tax US tax incentives Build Back Better tax rate on gilti Global Intangible Low Tax Income (GILTI) Global intangible low-taxed income US cross-border tax reform and GILTI Global Intangible Low Tax Income. Foreign tax credits

JCT Analyzes Federal Revenue Effects of Pillar Two

The JCT analysis raises some useful questions for the U.S. domestic debate over Pillar Two. The Treasury Department should examine its support for an agreement that will reduce its own revenue intake. But it is also worth noting that the principal mechanism for the revenue reduction—the foreign tax credit—is a policy already baked into U.S. law, including the Republican-enacted global minimum tax from 2017. The OECD deal merely takes advantage of this longstanding feature.

6 min read