MNE Profits Archives - Page 2 of 2 - Kluwer International Tax Blog

Alienation of Shares, Double Taxation, International Tax Law, M&A and Reorganizations, MNE Profits, OECD, Real Estate, Tax Treaties, United Nations

Indirect transfers: What is an indirect interest in immoveable property in the natural resource sector, and what is it worth?

Jonathan Schwarz (Temple Tax Chambers; King’s College London)/August 1, 2019 /Leave a comment

Two of my recent articles have examined the Australian decision in Commissioner of Taxation v Resource Capital Fund IV LP [2019] FCAFC 51. The articles examine the central question on the source of income earned and the tax classification and entitlement to treaty benefits of investment funds. Real property gains This time I consider two…

BEPS, Digitalization, MNE Profits, OECD

The OECD/Inclusive Framework’s Program of Work on Revised Nexus and Profit Allocation Rules (Pillar One): Where Will It Lead?

Jefferson VanderWolk, Robert O'Hare (Squire Patton Boggs)/June 25, 2019June 24, 2019 /Leave a comment

On June 9, 2019 the G20 finance ministers endorsed the program of work that was issued by the OECD’s Inclusive Framework on BEPS on May 31, 2019 in relation to tax challenges arising from the digitalization of the economy. As expected, the program of work has two parts. The first part, called Pillar One, aims…

Germany, MNE Profits, Tax Policy

The German Proposal for an Effective Minimum Tax on MNE Profits

Johannes Becker, Joachim Englisch (University of Muenster)/January 17, 2019January 14, 2019 /Leave a comment

According to an undisclosed policy paper that is currently circulated within the OECD, the German government is promoting an internationally coordinated reform of corporate taxation. Specifically, Germany proposes an effective minimum tax on the profits of multinational companies. Complex, easy to manipulate and unfair – there is widespread discontent with the current system of international…