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Just when the world thought it was on the cusp of a global tax breakthrough, cracks are beginning to show.
The landmark OECD agreement aimed at overhauling how multinational companies are taxed is facing renewed opposition – and much of the resistance is coming from the United States.
This could have major implications for how, when, and even if the deal is implemented.
The OECD’s two-pillar framework was designed to tackle tax avoidance and ensure large multinationals pay a fairer share of tax, wherever they operate.
Pillar One reallocates taxing rights so market countries can tax a portion of profits.
Pillar Two introduces a global minimum corporate tax rate of 15% for companies with annual revenues above €750 million.
Over 135 countries, including the US, have committed in principle. But turning that agreement into domestic law is proving to be the real challenge.
Although the Biden administration supported the OECD framework, political realities have changed.
With a divided Congress and strong Republican opposition, passing necessary legislation has become difficult.
Critics in the US argue that the global minimum tax could hurt American competitiveness by effectively outsourcing tax sovereignty.
There’s also concern that other countries are implementing Pillar Two but dragging their feet on Pillar One – potentially putting US firms at a disadvantage.
US hesitancy could derail the entire project.
Other countries, particularly in the EU and Asia, are moving forward with minimum tax rules.
If the US doesn’t follow suit, it undermines the whole concept of a level playing field.
There’s also a risk that disputes over digital taxes, which Pillar One was supposed to resolve, could flare up again if countries lose patience with the OECD timetable.
All eyes are now on the US Congress and upcoming elections.
Without US implementation, the deal lacks weight — and countries may return to unilateral measures like digital services taxes.
This would be a setback for international cooperation and tax certainty.
The global tax deal was a diplomatic achievement, but its future is far from guaranteed.
If the US backs away or delays indefinitely, other countries may rethink their own commitments — and the dream of a fairer global tax system could stall once more.
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The UK government is exploring ways to reduce the burden of its digital services tax (DST) on American tech giants as part of broader trade discussions with the United States.
The move comes amid rising international pressure and a growing consensus that digital taxation should be handled multilaterally through the OECD framework.
The UK’s DST, introduced in 2020, imposes a 2% levy on the revenues of large digital businesses that earn money from UK users.
This includes revenues from search engines, social media platforms, and online marketplaces.
The tax applies to companies with global revenues over £500 million and at least £25 million of UK-derived revenue.
Recent reports suggest the UK is considering adjustments or possible early withdrawal of the DST to avoid escalating tensions with the US, which has long criticised the tax as unfairly targeting American firms.
The US has threatened retaliatory tariffs against UK exports if the DST remains in place beyond the implementation of the OECD’s global tax framework.
As trade talks progress, the UK may offer concessions to secure a broader deal.
Under the OECD’s two-pillar agreement, countries that have introduced unilateral digital taxes are expected to remove them once Pillar One (which reallocates taxing rights over digital profits) is implemented.
The UK has committed to this, but with the global deal’s timeline uncertain, there’s growing pressure to act sooner.
Domestically, opinions are split.
Some MPs and economists argue that the DST is necessary to ensure tech giants pay their ‘fair share’, especially during times of economic strain.
Others argue that it’s a temporary fix and should be removed in favour of multilateral rules that apply consistently across jurisdictions.
Any softening of the DST is likely to be politically controversial.
However, it may help the UK achieve its long-term goal of securing a comprehensive trade agreement with the US – and could also pre-empt future disputes if Pillar One implementation drags.
The UK’s digital services tax has always been a stopgap measure.
With global reforms on the horizon and trade talks with the US intensifying, its days may be numbered – either replaced by multilateral rules or scrapped to preserve trade harmony.
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Scotland’s ability to manage its own finances has come under scrutiny following an OECD recommendation that Scottish politicians receive formal financial training.
The international body argues that members of the Scottish Parliament (MSPs) lack the economic and tax expertise needed to make informed policy decisions, leading to concerns about the effectiveness of budget oversight and the potential for financial mismanagement.
The proposal comes at a time when Scotland is grappling with increasing fiscal autonomy, particularly after the 2016 Scotland Act, which granted Holyrood significant control over income tax, welfare spending, and other financial matters.
However, critics argue that some MSPs have struggled to grasp the complexities of tax legislation, borrowing powers, and the long-term economic impact of policies.
The OECD’s recommendation is based on a wider review of how well governments understand and manage public finances.
Scotland, despite its devolved powers, has no formal training requirements for MSPs on tax or economic policy. This has led to instances where:
A recent review of Scotland’s budget process also raised concerns about transparency, with some MSPs reportedly uncertain about the long-term impact of tax decisions.
The OECD argues that a basic level of financial literacy should be a prerequisite for holding office, especially given that Scotland now raises a significant proportion of its own revenue rather than relying solely on Westminster allocations.
The Scottish government has acknowledged the OECD’s concerns but argues that many MSPs already undergo financial briefings. However, opposition parties and some economists have welcomed the recommendation, with calls for mandatory financial training upon election.
A key question is how such training would be implemented. Some proposals include:
There is also the issue of political willingness. While many acknowledge the value of financial literacy, others argue that training should not be compulsory, as MSPs already have access to expert advice from civil servants and economic advisors.
Scotland’s evolving tax and financial system requires well-informed decision-makers, and the OECD’s recommendation highlights a genuine gap in expertise among politicians.
While some MSPs may resist the idea of mandatory financial training, there is a strong argument that better economic literacy could improve the quality of policymaking and budget scrutiny.
If Scotland is to make the most of its devolved powers, ensuring that MSPs fully understand the tax and spending decisions they are making is essential.
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The OECD has unveiled a new tool to simplify transfer pricing calculations under the “Amount B” framework.
This development aims to reduce administrative burdens and improve compliance for businesses engaged in cross-border transactions.
The Amount B framework, part of the OECD’s broader initiatives on Base Erosion and Profit Shifting (BEPS), standardises the remuneration for baseline marketing and distribution activities.
The newly released tool automates the calculation of these returns, requiring minimal data inputs from businesses.
For multinational corporations, the tool offers significant advantages. It reduces the time and resources needed for compliance, ensures consistent application of transfer pricing rules, and minimizes the risk of disputes with tax authorities.
Tax professionals have welcomed the tool as a step toward greater simplicity and transparency in transfer pricing.
However, they caution that the tool’s effectiveness depends on its adoption by tax authorities worldwide.
Consistent application across jurisdictions will be essential to avoid double taxation and unnecessary compliance burdens.
This tool is particularly relevant for companies with extensive global operations, as it addresses common pain points in transfer pricing compliance.
It reflects the OECD’s commitment to creating practical solutions that align with international tax standards.
The OECD’s pricing automation tool for Amount B represents a significant advancement in simplifying transfer pricing compliance.
By reducing complexity and enhancing transparency, it should foster greater trust between businesses and tax authorities.
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With Donald Trump eyeing another term as U.S. president, the international tax landscape could face significant turbulence.
Trump’s administration has hinted at targeting countries that impose additional taxes on U.S. multinationals.
This raises concerns about retaliatory tariffs and potential conflicts over the OECD’s global minimum tax pact, which aims to ensure large companies pay at least 15% tax wherever they operate.
The OECD’s two-pillar tax reform seeks to address long-standing challenges in taxing multinational corporations.
While many countries, especially in the EU, are implementing these reforms, U.S. Republicans claim the measures unfairly target American companies.
Trump’s administration could respond with punitive tariffs, potentially triggering global economic disputes.
The US plays a crucial role in global economic stability.
A confrontational approach to international tax rules could fragment global cooperation and undermine the OECD’s efforts to harmonize tax systems.
Businesses caught in the crossfire will need robust strategies to navigate these uncertainties.
Trump’s potential return to power adds a layer of unpredictability to the already complex global tax landscape.
As the world adjusts to new tax norms, balancing domestic interests with international commitments will be key to maintaining stability.
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The way multinational corporations (MNCs) are taxed has long been a topic of debate.
With the rise of the digital economy, traditional tax rules have struggled to keep pace, allowing some companies to minimize their tax liabilities by operating in low-tax jurisdictions while earning substantial revenues elsewhere.
Enter the OECD’s Pillar One, a groundbreaking effort to ensure fairer taxation of MNCs by reallocating taxing rights to market jurisdictions.
This article explains what Pillar One is, how it works, and what it means for businesses and governments worldwide.
Traditionally, corporate taxes are paid where a company has a physical presence, such as an office or factory.
However, in the digital era, companies can generate significant profits in countries without having a physical footprint, leaving those countries with little or no tax revenue.
This issue is particularly evident with tech giants that provide digital services globally but pay minimal taxes in the markets they serve.
The lack of a global framework to address this has led to unilateral measures like digital services taxes (DSTs), which complicate international trade and risk double taxation.
Pillar One seeks to address these issues by establishing a standardized global approach.
Pillar One is part of the OECD’s Two-Pillar Solution to address the tax challenges of the digital economy.
It focuses on reallocating taxing rights so that countries where consumers or users are based can claim a share of the tax revenue from the profits generated there.
Despite its ambition, Pillar One faces several hurdles:
Pillar One represents a seismic shift in global taxation.
For governments, it promises fairer tax revenues from MNCs operating in their markets.
For businesses, it provides a unified framework that reduces the risks of fragmented and overlapping tax regimes.
While it may require significant adaptation, Pillar One seeks to create a more equitable and predictable global tax system.
Pillar One is a bold and necessary step toward addressing the challenges of taxing the digital economy.
By reallocating taxing rights to market jurisdictions, it aims to ensure that profits are taxed where value is created.
However, successful implementation will require unprecedented global cooperation and careful management of potential pitfalls.
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Thailand has taken steps to align itself with global tax standards by approving a draft law to implement a 15% global minimum corporate tax.
This measure targets multinational corporations with annual global revenues exceeding €750 million, aiming to ensure fairer taxation and reduce profit-shifting to low-tax jurisdictions.
The global minimum tax is part of a broader effort spearheaded by the OECD to address base erosion and profit shifting (BEPS).
The aim is to ensure that large multinational enterprises (MNEs) pay a minimum level of tax regardless of where they operate. By implementing this measure, Thailand seeks to:
Thailand’s adoption of the 15% minimum tax reflects its commitment to global economic cooperation.
The reform aligns the country with over 140 jurisdictions that have pledged to implement the OECD’s tax framework.
While the reform is seen as a progressive step, it raises questions about its impact on Thailand’s investment attractiveness. Key considerations include:
Thailand’s approval of the global minimum corporate tax signals its dedication to modernizing its tax system and fostering international cooperation.
However, the measure’s success will depend on effective implementation and balancing revenue generation with maintaining investment appeal.
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Country-by-Country Reporting (CbCR) is a tax transparency measure introduced by the OECD as part of its Base Erosion and Profit Shifting (BEPS) initiative.
CbCR requires large multinational companies to report detailed information about their operations, profits, and taxes paid in each country where they do business.
This information is then shared with tax authorities to help them detect tax avoidance practices, such as profit shifting to low-tax jurisdictions.
CbCR applies to multinational companies with global revenues of more than €750 million.
These companies must file an annual CbCR report that provides a breakdown of their income, profits, taxes paid, and other economic activities in each country where they operate.
For example, if a company has subsidiaries in 10 different countries, it must provide information on how much revenue each subsidiary earns, how much profit it makes, and how much tax it pays in each country.
This level of detail helps tax authorities identify where a company might be shifting profits to avoid taxes.
as introduced as part of the OECD’s effort to tackle tax avoidance by multinational companies.
Before CbCR, it was difficult for tax authorities to see the full picture of a company’s global operations.
By requiring companies to disclose their activities on a country-by-country basis, CbCR gives tax authorities the information they need to detect tax avoidance schemes.
This reporting helps ensure that multinational companies are paying their fair share of taxes in the countries where they actually do business, rather than shifting profits to tax havens.
Country-by-Country Reporting is a critical tool for improving tax transparency and combating tax avoidance.
By requiring large multinational companies to report detailed information about their global operations,
CbCR helps tax authorities ensure that companies are paying their fair share of taxes and operating in a fair and transparent manner.
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The OECD has published new technical guidelines to assist countries in implementing the global minimum corporate tax rate of 15%.
This initiative aims to ensure that multinational corporations contribute a fair share of taxes, regardless of where they operate.
The technical guidance addresses several challenges, including calculating effective tax rates, identifying low-tax jurisdictions, and handling cross-border complexities.
It also provides a framework for dispute resolution between nations.
The guidelines will require multinationals to reassess their tax strategies, particularly those involving low-tax jurisdictions.
Compliance costs are expected to rise, but the rules aim to create a more level playing field globally.
Countries with tax-friendly regimes may resist adopting these guidelines, fearing a loss of competitiveness.
Additionally, differing interpretations of the rules could lead to disputes between jurisdictions.
The OECD’s technical guidance is a significant step towards implementing a global minimum tax. While challenges remain, this initiative represents a milestone in international tax cooperation.
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