International

  • March 11, 2024

    New Zealand Panel Urges 2025 Start For Global Minimum Tax

    The New Zealand Parliament should include a 2025 start date for implementing the Organization for Economic Cooperation and Development's global minimum tax plan as part of a wider bill, a government committee said Monday.

  • March 11, 2024

    Singapore Telecom Loses $201M Aussie Transfer Pricing Fight

    A Singapore telecommunications company's Australian subsidiary is liable for a tax bill of AU$304 million ($201 million), including interest and penalties, after an Australian appellate panel upheld a ruling that disallowed deductions for the subsidiary's interest payments to a Caribbean affiliate.

  • March 11, 2024

    Danish Prosecutors Open Tax Fraud Trial Against Sanjay Shah

    Prosecutors in Denmark opened the criminal trial on Monday of a British hedge fund trader accused of masterminding a £1.44 billion ($1.85 billion) tax fraud scheme. 

  • March 08, 2024

    Colombia Issues Guidance On Wealth, Environment Taxes

    Colombia's new wealth tax and adjustments to environmentally focused taxes passed in a wide-ranging 2022 bill were among the subjects of guidance published by the country's tax agency.

  • March 08, 2024

    States Must Nix Worldwide Combined Reporting, COST Says

    States showing glimmers of interest in the corporate tax reporting regime known as mandatory worldwide combined reporting are going down the wrong path as are the think tanks that support the method, the Council on State Taxation said in a report released Friday.

  • March 08, 2024

    HMRC Can Seek Identity Of Data Suit Financier

    A London court rejected on Friday an attempt to terminate U.K. government arguments for disclosing the identity of a financier backing a former U.S. citizen's claim that the transfer of some of her banking data by HM Revenue & Customs back to the U.S. violated her rights.

  • March 08, 2024

    BakerHostetler Hires Tax Partner From Moses & Singer

    BakerHostetler has added a partner from Moses & Singer LLP to its tax practice group and private wealth planning team.

  • March 08, 2024

    Taxation With Representation: Fried Frank, Latham

    In this week's Taxation with Representation, Viavi acquires Spirent, Cadence Design Systems purchases Beta Cae Systems International, and United Rentals buys Yak.

  • March 08, 2024

    ECB Urges EU Tax Measures To Boost Capital Market

    The European Central Bank has urged the bloc's finance ministers to agree on a new law on refunds on withholding tax and to eliminate the favorable treatment in national tax systems of corporate financing with debt over equity.

  • March 08, 2024

    'Non-Dom' Tax Reforms Should Keep UK Lawyers Busy

    The government's decision to reform its 200-year-old "non-dom" tax regime to raise £2.7 billion ($3.4 billion) a year presents a short-term boom for tax lawyers expecting a rush of calls from existing and future clients looking for guidance on a new set of rules.

  • March 07, 2024

    Southern Peaks Awarded $42.5M Over Peruvian Copper Deal

    Peruvian copper producer Southern Peaks Mining LP said it has won a multi-million-dollar arbitral award favoring its management subsidiary due to breaches of a sale and purchase agreement with Singaporean commodity trading company Trafigura Beheer BV over the acquisition of a mine.

  • March 07, 2024

    Don't Let Pillar 1 Die, Policy Experts Tell House Tax Panel

    Tax policy experts encouraged a U.S. House subcommittee Thursday to continue negotiations at the Organization for Economic Cooperation and Development over the taxing rights overhaul known as Pillar One and advocate for stronger double taxation relief and tougher language eliminating digital service taxes.

  • March 07, 2024

    Indian Gov't Eyes Linking Carbon Tax On Coal To Quality

    The Indian government should consider linking its carbon tax on coal to quality and price rather than weight because the current system gives an advantage to imported coal over domestic coal, the country's Ministry of Coal said Thursday.

  • March 07, 2024

    UAE Implementing Income Tax On Foreign Banks In Dubai

    Foreign banks operating in Dubai — except for those operating in one special economic jurisdiction — must pay a 20% income tax, according to a law signed by the United Arab Emirates' prime minister Thursday.

  • March 07, 2024

    Spotify Cites New Tax In Raising Subscription Fee In France

    Spotify will raise the price of subscriptions in France to what it said will be the most expensive in the European Union in response to a new French tax earmarked for the country's Center for National Music, the streaming service said Thursday.

  • March 07, 2024

    5 Indicted In €54M VAT Fraud Involving 10,000 Cars

    Authorities indicted five suspects arrested in connection with a scheme involving the international trade of more than 10,000 cars that resulted in €53.7 million ($58.7 million) in value-added tax fraud, the European Public Prosecutor's Office said.

  • March 07, 2024

    EU Pressure May Push Germany To Align VAT Law For Tutors

    Pressure from the European Commission may force Germany to align its law on value-added tax with the European Union's VAT law and thus make it easier for private tutors to receive a VAT exemption they're entitled to under EU law.

  • March 07, 2024

    EU Parliament Panel Backs Duty-Free Imports From Ukraine

    The European Parliament's international trade committee voted on Thursday to extend the suspension of EU customs duties and quotas on Ukrainian imports for one more year.

  • March 07, 2024

    Biden Urges Higher Taxes On Wealthy Companies, Individuals

    President Joe Biden, in his Thursday night State of the Union address, urged Congress to make the U.S. tax code fairer by enacting higher rates on wealthy corporations and individuals and extending tax relief to working families.

  • March 06, 2024

    Impending Corp. Spinoff Guidance Could Refine Tax-Free Test

    Tax attorneys are watching to see if eagerly awaited corporate spinoff guidance will help determine whether transactions qualify for tax-free status with more clarity than current regulations, and without controversial bright-line rules that were floated several years ago.

  • March 06, 2024

    Startup Investors' Attys Want $1.5M In Fees On Disclosure Suit

    Lawyers for a class of investors have asked a New York federal court to approve their attorney fees of $1.5 million for a $4.5 million settlement with a Chinese analytics startup over claims the company misrepresented its tax liability before its initial public offering. 

  • March 06, 2024

    Suspect Charged In €42M Italian VAT Fraud Scheme

    A suspect was placed under house arrest by Italian authorities and charged with €41.8 million ($45.6 million) in value-added tax fraud involving the wholesale trade of computer equipment, as well as the misappropriation of €6.7 million in public funds, the European Public Prosecutor's Office said Wednesday.

  • March 06, 2024

    HMRC Estimates UK's 2022-23 VAT Gap At £8.6B

    An updated estimate by HM Revenue & Customs released Wednesday put the gap between the amount of value-added tax the U.K. expected to collect in the 2022-23 tax year and the amount actually collected at £8.6 billion ($10.96 billion).

  • March 06, 2024

    UK Cuts Tax, Reforms Non-Dom Rules In Pre-Election Budget

    The U.K. government unveiled another cut in payroll taxes and changes to rules on non-domicile status on Wednesday as it presented its election-year spring Budget.

  • March 06, 2024

    EU Proposes VAT Exemption For Joint Arms Purchases

    The European Commission proposed an exemption from value-added tax for arms procurement when European Union countries band together in joint purchase programs, part of a broad strategy to boost the bloc's defense capabilities.

Expert Analysis

  • How The OECD Global Tax Proposal Could Affect M&A

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    Following agreement on the Organization for Economic Cooperation and Development’s Pillar Two proposal to introduce a global minimum tax, domestic implementation is expected to have a significant impact on international M&A transactions, with financial modeling, deal structuring, risk allocation and joint venture arrangements likely to be affected, say lawyers at Freshfields.

  • UK Shares-Tax Proposals Offer Long-Awaited Modernization

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    The U.K. government's recent consultation on the introduction of a new tax on transactions in securities raises detailed legal and practical issues, but the prospect of a single digital stamp tax offering both streamlined legislation and administration will be welcomed, say Zoë Arnautov and Mark Sheiham at Simmons & Simmons.

  • IRS Foreign Tax Credit Pause Is Welcome Course Correction

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    A recent IRS notice temporarily suspending application of 2022 foreign tax credit regulations provides wanted relief for the many U.S. multinational companies and other taxpayers that otherwise face the risk of significant double taxation in their international operations, say attorneys at Mayer Brown.

  • IRS Criminal Probe Spells Uncertainty For Malta Pension Plans

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    The IRS’ recent scrutiny of Malta pension plan arrangements — and its unusual issuance of criminal administrative summonses — confirms that it views many of these plans as illegal tax evasion schemes, and the road ahead will not be smooth and steady for anyone involved, say attorneys at Kostelanetz.

  • IRS Announcement Will Aid Cos. In Buyback Tax Planning

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    Recent IRS transitional guidance regarding current requirements for reporting and payment of the stock repurchase excise tax will help corporate taxpayers make decisions about records retention and establishing reserves for future tax payments, say Xenia Garofalo and Kyle Colonna at Eversheds Sutherland.

  • Flawed Analysis Supports Common Law Tax Deficiency Ruling

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    The Colorado federal district court’s recent decision in Liberty Global, holding that the U.S. Department of Justice may assert a common law tax claim without the notice of tax deficiency required by the Internal Revenue Code, relies on a contorted reading of the statute and irrelevant case law, say Loren Opper and Christie Galinski at Miller Canfield.

  • Review Of Repatriation Tax Sets Justices On Slippery Slope

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    The U.S. Supreme Court’s recent decision to review the constitutionality of the repatriation tax in Moore v. U.S. has implications for many tax rules involving unrealized amounts and could leave the court on the brink of invalidating large swaths of the Internal Revenue Code, say attorneys at Eversheds Sutherland.

  • What To Make Of IRS' New Advance Pricing Guidance

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    Recent guidance on the IRS' goals for its advance pricing agreement system provides helpful insight into review and decision-making procedures for advance pricing agreement requests, but it also raises questions about the IRS' objectives, say Richard Slowinski and Stefanie Kavanagh at Alston & Bird.

  • Reserved Investor Fund Would Plug Gap In UK Finance Market

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    The reserved investor fund recently proposed by HM Treasury has the potential to be a welcome tax-efficient addition to the U.K.’s canon of products for real estate investments, with attractive features for companies and, in particular, large asset managers, say lawyers at Herbert Smith.

  • The Reciprocal Tax Bill Is A Warning Shot At Pillar 2

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    A bill recently introduced in the House of Representatives to reciprocally tax countries deemed to have imposed discriminatory taxes on U.S. citizens and businesses takes aim at countries implementing the global minimum tax treaty known as Pillar Two, with which the U.S. has not complied, says Alan Cole at the Tax Foundation.

  • What Tax-Exempt Orgs. Need From Energy Credit Guidance

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    Guidance clarifying the Inflation Reduction Act’s credit regime, expected from the U.S. Department of the Treasury this summer, should help tax-exempt organizations determine the benefits of clean energy projects and integrate alternative energy investments into their activities, say attorneys at Morgan Lewis.

  • How Foreign Info Return Penalty Case May Benefit Taxpayers

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    The U.S. Tax Court's recent decision that the Internal Revenue Service cannot penalize taxpayers for failing to file foreign corporation information returns may give similarly situated taxpayers an opportunity to also avoid penalties, provided they protect their rights before the decision is overturned or mooted by legislation, say attorneys at Arnold & Porter.

  • The Nuts And Bolts Of IRS Domestic Content Tax Credit

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    Recent IRS guidance provides specifics on how renewable energy projects can qualify for bonus tax credits by meeting U.S. domestic content rules, but also creates a qualification framework that will be complicated for project developers to navigate, say Scott Cockerham and Wolfram Pohl at Orrick.

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