Taxation of Multinational Businesses

Join Us for a Free “State Tax Policy Boot Camp”

The Tax Foundation’s “State Tax Policy Boot Camp,” is ideal for anyone interested in gaining a better understanding of state taxation.

An “Interest”ing Tax Hike in the COVID-19 Relief Proposal

As the House Ways and Means Committee continues working on the latest round of fiscal relief amid the pandemic, one curious provision in the legislation is a tax hike on multinational companies. One section of the legislation would repeal a provision in current law that allows U.S. multinationals to choose to allocate their interest costs on a worldwide basis (more on that in a moment).

The European Commission and the Taxation of the Digital Economy

The consultation on the EU’s digital levy provides an opportunity for policymakers and taxpayers to reflect on the underlying issues of digital taxation and potential consequences from a digital levy. Unless the EU digital levy is designed with an OECD agreement in mind, it is likely to cause more uncertainty in cross-border tax policy.

Tax Foundation Response to OECD Public Consultation Document: Reports on the Pillar One and Pillar Two Blueprints

The Tax Foundation response to the OECD public consultation document on the reports on the OECD Pillar 1 and OECD Pillar 2 blueprints.

Corporate Tax Rates Around the World

What is driving the downward trend in corporate tax rates and will it continue? Is it truly a race to the bottom? Why do corporate tax rates matter in the first place? How does the U.S. rate compare and could that change in the coming years?

Comparing Europe’s Tax Systems: International Tax Rules

International tax rules define how income earned abroad and by foreign entities are taxed domestically, making them an important element of a country’s tax code.

Two Roads Diverge in the OECD’s Impact Assessment

The difference that the OECD presents between the potential impact in the context of agreement compared to a harmful tax and trade war should show policymakers the value of continuing multilateral discussions.

Pillars, Blueprints, an Impact Assessment, and Construction Delays

The OECD released blueprints for proposals on changing international tax rules alongside an impact assessment based on the overall design of the proposals. While the blueprints cover proposals both for changing where large multinationals owe corporate tax and designing a global minimum tax, there are still many unanswered questions. In the meantime, other digital tax proposals are moving forward and have the potential to result in a harmful tax and trade war.

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.

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.

Repatriation

Territorial Tax System

Worldwide Tax System

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.

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.

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.

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.

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.

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.

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.