Biden’s Plan to Address Offshoring Comes with Contradictions
If the goal of the Biden campaign is to bring new investment and jobs to the U.S., it is doubtful that these new tax rules will contribute to that goal.
4 min read
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Thin-Cap Rules in Europe
To discourage a certain form of international debt shifting, many countries have implemented so-called thin-capitalization rules (thin-cap rules), which limit the amount of interest a multinational business can deduct for tax purposes.
4 min read
Challenges for Transfer Pricing in an Economic Downturn
Transfer pricing rules are under stress given the current economic crisis. The OECD should provide transfer pricing guidance during the coronavirus crisis.
13 min read
Summary of the OECD’s Impact Assessment on Pillar 1 and Pillar 2
The OECD presented its preliminary impact assessment on the Pillar 1 and Pillar 2 proposals. The impact assessment includes estimated revenue and investment effects presented at a country group level (low-, middle- and high-income countries and investment hubs). The OECD estimates global corporate income tax revenues to increase by 4 percent if both pillars get implemented, equaling $100 billion annually.
4 min read
Comparison of Cross-Border Effective Average Tax Rates in Europe and G7 Countries
As policymakers consider ways to facilitate investment, effective average tax rates provide a valuable perspective on where burdens on those activities are high and where they are low.
16 min read
How Controlled Foreign Corporation Rules Look Around the World: Colombia and a Perspective of Latin America
For Colombia, as well as for other countries in the world that are not capital exporters, one important question is whether CFC rules are necessary or are indirectly a requirement to be part of world organizations like the OECD (which Colombia is not a member) in order to be on the radar of larger economies.
5 min read
How Controlled Foreign Corporation Rules Look Around the World: Germany
Germany has had a Controlled Foreign Corporation (CFC) regime since 1972, when the German Foreign Transactions Tax Act was enacted. Under the German regime, a CFC is a foreign company where its capital or voting rights are either directly or indirectly majority-owned by German residents at the end of its fiscal year.
6 min read
Kansas, Nebraska, and Utah Lawmakers Pursue “Not GILTI” Verdicts
Taxing GILTI puts states at a competitive disadvantage compared to their peers—all for a tax that makes very little sense at the state level, and which legislators never sought in the first place.
5 min read
Bracing for Impact
Though they are limited by both data and assumptions, the OECD will face similar limitations. As policymakers work to fine-tune the proposals under both Pillar 1 and 2 the impact assessment should be a critical part of that discussion.
6 min read
How Controlled Foreign Corporation Rules Look Around the World: Spain
The CFC legislation in Spain is not as complicated as it is in some other countries, and it is aligned with the standards recommended by the OECD. The Spanish rules have evolved in a way that the rules are designed to comply with the EU principles not to interrupt the functioning of the Union and its single market.
4 min read
Profit Shifting: Evaluating the Evidence and Policies to Address It
The OECD has been working to assess the impact of their program of work, and it will be critical for this assessment to take into account impacts not only on revenues, but also on growth and investment.
7 min read
How Controlled Foreign Corporation Rules Look Around the World: France
In France, Controlled Foreign Corporation (CFC) rules were first enacted in 1980. The French tax regime operates on a strict territorial basis, where only profits generated in the country are subject to tax in France.
5 min read
How Controlled Foreign Corporation Rules Look Around the World: China
The Chinese approach to base erosion and profit shifting is more focused on the application of transfer pricing rules and not on the application of CFC rules. Even with the rules in place, the Chinese tax authorities have not enforced the rules as much as other countries have.
3 min read
Tax Foundation Response to OECD Public Consultation Document: Global Anti-Base Erosion Proposal (“GloBE”) (Pillar Two)
The tax base for the income-inclusion rule will be just as important as determining the rate, and both the base and the rate will likely impact business decisions. Additionally, policymakers need to determine how the choice for blending fits with the overarching goal of the policy. And as the example of GILTI shows, it is essential to assess how current international tax regulations would interact with a global minimum tax.
11 min read
Response to OECD Public Consultation Document: Secretariat Proposal for a “Unified Approach” under Pillar One
Unifying the proposal under sound principles in the context of clear economic analysis should allow the Inclusive Framework to minimize both the administrative and economic burdens that the Secretariat’s proposal could create.
12 min read