Digital services tax(es) and global profit reallocation

The latest addition to our series of brief insights into the workings of the UK and supranational bodies reviewing the taxation of digitalisation of business. This edition includes the UK's consultation on the implementation of digital platform reporting rules.

This edition includes an insight into Kenya's new ESS rules and a publication on AsiaPac's ESS and other indirect tax digital development path as well as some new VAT incentives in Thailand. An overarching Pillar 1 consultation may be announced in early July while the UK has confirmed that its Pillar 2 rules will apply to accounting periods beginning on or after 31 December 2023. Nepal and Tanzania are the latest countries to announce the potential introduction of digital services taxes. We also cover India Guidelines on application of WHT on transfer of crypto assets.

The latest addition to our series of brief insights into the workings of the UK and supranational bodies reviewing the taxation of digitalisation of business. This edition includes an OECD announcement on a delay to Pillar One, our latest Africa tax report that includes digital economy insights and a proposed 6% streaming levy in Denmark..There is also insight into the UK's proposal to introduce platform reporting rules with effect from 1 January 2024.

The OECD released the public consultation documents on the Amount A - Tax Certainty Framework for Amount A and Tax Certainty for Issues Related to Amount A on 27 May 2022.

This edition includes an OECD release on the IT format for sharing digital platform reporting information and an update on the EU attempts to adopt a Directive to implement Pillar Two. It also considers the relevance of 'nudge' letters being sent by the Indian tax authorities and the CJEU decision on Belgian tax reporting on tourist accommodation not being contrary to EU law.

The OECD released the public consultation document on the Pillar One - Amount A: Regulated Financial Services Exclusion on 6 May 2022. Comments on the consultation document are due by 20 May 2022. This alert provides a short overview of the proposed approach to the Regulated Financial Services Exclusion and some initial observations.

Where have we reached in this process? What uncertainties remain? And what reactions are we seeing? Join us on Friday 29 April at 2.30pm where our global tax policy team and subject specialists will discuss the latest guidance on global minimum tax (Pillar 2).

This edition includes publication of the Commentary on Pillar 2 GloBE Rules together with the status of attempts to implementation those rules across the EU and also in Switzerland. We focus too on the consultation on the Implementation Framework for the GloBE Rules and on a possible extension of the EU's blacklist criteria for non-cooperative jurisdictions regarding Pillar 2.

On 4 April 2022, the OECD released draft Model Rules for domestic legislation on the scope of Amount A of Pillar One. Comments to the draft Model Rules are due by 20 April 2022. This alert provides a short overview of the draft Model Rules and some initial observations.

The OECD's Pillar 2 rules will establish a global minimum tax regime which will apply to both public and privately held multinational groups with consolidated revenue over €750m. Global agreement has been reached to bring these rules into law during 2022 with the aim of them being in 2023.

This edition includes details of Pillar One consultations on Nexus/ Revenue Sourcing and on Tax Base plus the expectation of 11 similar papers and an imminent OECD Pillar Two consultation. We note also a push by the EU Council's French Presidency to see Pillar Two impacts in the EU. The US Trade Representative has meanwhile sent Canada comments on its pending DST. Singapore's Budget announced consideration of a domestic minimum top-up tax. The Danish government's proposed introduction of a streaming levy is also under the spotlight and we comment on the Dominican Republic's consultation on VAT on digital services provided by foreign suppliers. The UK is meanwhile consulting again on the possibility of an online sales tax. Malaysia is providing an amnesty covering late registration/payment of its tax on digital services.

The OECD released Commentary and illustrative Examples to the Pillar Two Model Rules (Model Rules) on 14 March 2022. This alert includes several highlights of what is, and is not, in the Commentary, plus some initial observations.

EU Finance Ministers met on 15 March to debate and ultimately vote on a compromise text covering the introduction of a minimum taxation by the EU Member States. While there was broad support for the compromise text, it was not supported unanimously.

On 18 February 2022, the OECD released draft Model Rules with respect to the Tax Base Determinations under Amount A of Pillar One. Comments to the draft Model rules are due by 4 March 2022. This alert provides a short overview of the draft Model Rules and some initial observations.

On 4 February 2022, the OECD released draft Model Rules with respect to nexus and revenue sourcing under Amount A of Pillar One. Comments to the draft Model rules are due by 18 February 2022. This alert provides a short overview of the draft Model Rules and some initial observations. It should be noted that this is the first in a series of several sets of rules that the OECD is expected to release over the coming months, with very short comment periods, as part of a 'rolling consultation'.

This edition includes the publication of Nigeria's Finance Act 2021 with tis effective 6% Digital Service Tax (DST).and the announcement by the UAE of a Federal corporate tax with rates potentially tailored to the Pillar Two minimum tax regime. We've seen the launch of an EU consultation on digital VAT, as well as of a Ukrainian Information Notice for VAT on e-services. We also comment on debates around an e-levy in Ghana and the optimism being shown in relation to changes to US GILTI.

Watch the latest in our Delivering Tax: Creating value in a changing world webcast series, where our panel explored the mechanics of the new Pillar 2 system, its effects on business and the interconnectivities with tax proposals from the Biden administration in the US.

This edition includes the publication by the Model Rules for the 15% minimum ETR under Pillar Two of the G20/OECD Inclusive Framework digitalisation project and by the European Commission on proposals to implementation them across the EU. There is also a warning from the Australian tax authorities for businesses to be prepared for Pillar One and Pillar Two changes. It also provides an update on the US Senate Finance Committee progress on the Build Back Better reconciliation bill, Canada consulting on its deferred DST, a Nigerian statement on the reasons they wouldn't sign the global deal and plans for Cyprus to increase its tax rate as a result of Pillar Two. The UK concluded its G7 presidency with an acknowledgement of the digital tax achievement.

The Indian Finance Ministry recently issued a press release announcing that it had agreed with the United States on a transitional approach to the 2% Indian Equalisation levy (the ‘Indian EL’ or digital tax) on e-commerce supply or services. The US Treasury also announced this agreement through a press release.

This edition includes further G20 endorsement of the Inclusive Framework Statement on 8 October. US progress on its own domestic tax plans has moved on with House approval of the reconciliation bill and it has reached similar DST compromise agreements with Turkey and India as with other DST countries previously. This edition also includes on digital services an update from Nigeria on easing the application of new VAT rules, further India guidance on collection at source mechanisms, Budget proposals from Malaysia on low value goods imports and tourism tax and a brief analysis of Georgia's new VAT rules..

This edition includes announcements around a new OECD/G20 Inclusive Framework Statement on 8 October, while the Irish Budget on 12 October gave a little more detail on Ireland's plans and G20 Finance Ministers gave a brief endorsement. A subsequent agreement then covered transitional relief for DSTs in UK, France, Italy, Spain and Austria while India seems to have indicated it will await 'implementation' of the deal. We also cover updates on the US domestic proposals which are linked to the deal, a Latvian proposal that would have introduced a DST and the news than Canada will progress its DST legislation but hold it in abeyance for now.

Following the OECD’s recent announcement that 136 countries, including Canada, had committed to fundamental changes to the international corporate tax system, Deputy Prime Minister and Minister of Finance, Chrystia Freeland, confirmed Canada’s commitment to this international agreement, and announced that Canada still intends to move ahead with legislation finalizing a digital services tax (DST) by 1 January 2022 (as announced in the federal government’s 2021 budget). However, the DST would only be imposed if the multilateral convention implementing Pillar One has not come into force by 31 December 2023. In that event, the DST would be payable as of 2024 in respect of revenues earned since 1 January 2022.

Austria, France, Italy, Spain, the United Kingdom and the United States have issued a joint statement on a compromise reached regarding digital services taxes and related unilateral measures. It follows the OECD Inclusive Framework statement of 8 October which contained details on unwinding existing DSTs and an agreement not to introduce further unilateral measures in the lead-up to the implementation of Pillar One.

On 8 October 2021, 136 countries of the 140 members of the OECD Inclusive Framework on Base Erosion and Profit Shifting committed to fundamental changes to the international corporate tax system. Read our flyers to find out more about why Pillar One and Two are so important.

On 8 October 2021, 136 out of the 140 countries of the OECD Inclusive Framework on Base Erosion and Profit Shifting (IF) politically committed to potentially fundamental changes to the international corporate tax system.

Watch this recording for a deeper discussion on how the recent developments with the OECD, Inclusive Framework and G20 might affect your business.

This edition includes the latest from both sides of the US Congress on international tax reform and from the Philippines Parliament on VAT for digital services, proposals from the Czech Ministry of Finance on reporting by platforms in accordance with DAC7, Vietnam's incoming regime that goes beyond reporting to require withholding at source and Pakistan's application of withholding tax to online marketplaces. Some recent developments in relation to VAT on e-services in South Africa warrant attention. Singapore has clarified aspects of its e-commerce GST regime.

This edition includes updates on reporting by platforms with the draft legislation on Australia's new Bill, UK consultation on its proposals and Malaysia's guidance on its tourism tax. On Pillars 1 and 2, the US Senate committee on finance has published for consultation its proposals on relevant international tax reform, Barbados has signed up to the IF Statement and Switzerland has reiterated conditions for signing. And Pascal St Amans has noted that not all taxes on digital transactions may be considered the same.

This edition includes the G20 agreement/ Inclusive Framework Statement, postponement of details of an EU digital levy, Canada's GST/HST draft legislation, Gibraltar's rate increase reaction to Pillar 2 and confirmation of assent to Kenya's Finance Act 2021. The IMF has also published a Technical Note on recommended VAT measures on imported digital services and low-value imported goods. A primer on deferred tax will help shed light on the related issues being discussed on the Pillar 2 discussions.

At the 9th - 10th July G20 meeting, the G20 endorsed the position reached by 132 of the 139 Inclusive Framework members to move forward with the two-Pillar approach and to begin work on the technical discussions in advance of the next OECD/IF and G20 meetings in October.

Please join us on Wednesday, 23 June 2021 at 1pm for a deeper discussion and understanding of how the G7 Finance Ministers’ agreement might affect your business.

A collection of the brief insights throughout June 2021 of the type provided on an ad hoc basis in our Latest digital tax byte update.

The G7 Finance Ministers announced an agreement on June 5, in which the participating countries committed to new taxing rights that allow countries to reallocate some portion of profits of large multinational companies to markets (i.e., where sales arise—'Pillar One’), as well as enact a global minimum tax rate of at least 15% (‘Pillar Two’). The meeting marked an early test of whether the US position on the OECD Inclusive Framework’s ‘Taxation of the Digitalising Economy’ project would provide momentum to finding a common base for agreement.

This edition includes announcements on India's SEP thresholds, Australia's proposed sharing economy reporting regime and revised USTR hearings on DSTs. The progress of US domestic proposals may impact on Pillar One and Two discussions and ATAF has put forward its revised proposals. The EC has released a Communication including its intentions on digital measures. Kenya's 2021 Finance Bill has proposed some changes to the definition of a PE, the DST and VAT rules while the IMF has released a paper on the challenges faced by countries in setting VAT rules.

A collection of the brief insights throughout April 021 of the type provided on an ad hoc basis in our Latest digital tax byte update.

Digital Service Taxes, or DSTs, have been permeating the trade environment since 2018, but COVID-19 and the OECD’s digitalization of the economy project, commonly referred to as BEPS 2.0, have accelerated the focus on DSTs. The stated aim of DSTs is to ensure that “market” countries get increased taxing rights over the profits of tech-based multinational companies that sell into their local market, and collect data from and target advertisements at local audiences, regardless of their physical presence.

PwC has welcomed the opportunity to share its views on the consultation document on the Digital levy which aims to provide COVID-19 recovery resources for the European Union.

Legislation passed by the Maryland General Assembly on the last day of the regular session (April 12) delays the state’s digital advertising gross revenue tax by one year and retroactively amends the state’s digital products sales tax provisions. Because of questions raised by litigation challenges to the Maryland digital advertising tax under the federal Internet Tax Freedom Act and the US Constitution and the lack of guidance from the Comptroller on how to source digital ad revenue, a delay has been expected.

A collection of the brief insights throughout March 2021 of the type provided on an ad hoc basis in our Latest digital tax byte update.

In a time when information is key and compliance is vital, GlobalDigitalTaxOnline (GDTO) is an essential tool to help navigate the complex world of tax and the reporting of various digital/electronic services.

A collection of the brief insights throughout February 2021 of the type provided on an ad hoc basis in our Latest digital tax byte update.

As part of the ongoing work to develop a solution to the tax challenges of the digitalisation/ globalisation of the economy, the OECD/G20 Inclusive Framework on BEPS published Blueprint Reports in October, with a deadline for comments of 14 December and held two days of virtual public meetings on 14 and 15 January. These public consultation meetings sought to focus on the key questions identified in the consultation document, particularly regarding simplification options and ideas.

A collection of the brief insights throughout January 2021 of the type provided on an ad hoc basis in our Latest digital tax byte update.

Welcome to our first edition for 2021 on recent developments in international and treasury tax of interest to multinationals operating in the UK. The edition covers the OECD publication of submissions on Pillars One and Two, the release of information on the follow-up public meeting and Italy's publication of some draft guidance.

Italy’s digital services tax became effective January 1, 2020, with a sunset clause linked to the outcomes of the OECD’s Pillars. Businesses that earn Italian digital revenues above certain thresholds are subject to the tax, and a traditional ‘nexus’ is not required. For FY 2020, the 3% tax must be paid by February 16, 2021 and a specific tax return must be filed by March 31, 2021.

A collection of the brief insights throughout December 2020 of the type provided on an ad hoc basis in our Latest digital tax byte update.This month saw submissions to the OECD in response to the consultation on the Pillar One and Two Blueprints, updates from Canada, Italy and Singapore in relation to DSTs and the attempt to open discussions between the European Commission and the new US administration on digitalisation issues.

Welcome to our last update for 2020 on recent developments in international and treasury tax of interest to multinationals operating in the UK. This edition includes EU agreement on more transparency rules for digital platforms (DAC7) and Canada's intention to introduce a digital service tax (DST) if no global measures are agreed. We wish you all a very happy and peaceful Festive break and we'll back back in January 2021 with a bumper edition.

The Canadian Deputy Prime Minister and federal Minister of Finance, Chrystia Freeland, recently presented the 2020 Federal Fall Economic Statement. The economic statement does not change personal or corporate income tax rates. This Tax Insights discusses the tax initiatives proposed in the economic statement, including the intention to bring forward a digital service tax (DST) from January 2022 if there are no appropriate global measures.

A collection of the brief insights throughout November 2020 of the type provided on an ad hoc basis in our Latest digital tax byte update. This month's update include's an update on India's expanded equalisation levy.

A collection of the brief insights throughout October 2020 of the type provided on an ad hoc basis in our Latest digital tax byte update. This edition includes guidelines from the African Tax Administration Forum (ATAF) on digital services taxes (DSTs) for African countries, the approval of spain's DST ,a statement from France on its intention to start collecting its DST again in December and a commitment from Belgium's new coalition government to implement a DST if no international solution is achieved by 2023. In that regard, the OECD published Blueprints for Pillars 1 and 2 (and the “chapeau” document announcing a delay to mid-2021) and held a follow-up webinar. The committee of UN tax experts also put forward its revised proposals. The European Commission said it would wait to see the OECD process play out but that there would be no further delay after that before it takes direct action. A recording of a PwC webcast to discuss the Blueprints is now available.

As part of the project on Tax Challenges Arising from Digitalisation, the OECD/G20 Inclusive Framework on BEPS announced on Monday, 12 October 2020 that it is seeking public comments on the Reports on the Pillar One and Pillar Two Blueprints. Register below to join us on Friday, 16 October for a webcast to discuss this important milestone in the digitalisation/globalisation project and to see our initial reactions in a short video.

After a lengthy legislative process, on October 16 the digital services tax and the financial transactions tax laws were published in the Spanish Official Gazette. Both laws will enter into force on January 16, 2021.

A collection of the brief insights throughout September 2020 of the type provided on an ad hoc basis in our Latest digital tax byte update. This edition includes news that the Blueprints for Pillars One and Two will be released shortly with consultation on various aspects to follow while an EU online event included comments on how various EU actors view the status of the project.

A collection of the brief insights throughout August 2020 of the type provided on an ad hoc basis in our Latest digital tax byte update. This edition includes an update on the latest thinking on Pillar 1 and Pillar 2 of the project on the digitalisation/ globalisation of the economy (and the circulation of draft blueprints to Inclusive Framework member countries).

A collection of the brief insights throughout July 2020 of the type provided on an ad hoc basis in our Latest digital tax byte update. This edition includes the Finance Bill Report Stage debate on the UK digital services tax (DST) and Royal Assent on 22 July plus a call for evidence on the possibility of imposing a UK online sales tax. It also covers OECD reports to the G20, the resulting G-20 Communique and references in an OECD update webcast as well as developments from the US Trade Representative's office on sanctions on France and on others imposing DSTs.

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. In addition to COVID-19 developments, this issue also includes: EU MDR - updates on further enactments and deferrals of the reporting deadlines; OECD Digital Tax Project: Profit Reallocation—How Do We Get ‘There’ From ‘Here’? and US developments - including final and proposed regulations regarding GILTI, subpart F and s163(j).

Recently, the number of taxation regimes for companies under the Kenya Income Tax Act (ITA) significantly increased. The main corporate tax changes include the introduction of the minimum tax and the digital services tax. The ITA already included regimes for withholding taxes, corporate income tax, capital gains tax, residential rental income tax, and a turnover tax, among others.

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. Amongst the items in this edition are legislative developments in the UK (including Royal Assent to the Finance Bill 2020), Tax Talks Webcast; a win for the taxpayer in the EU Apple case and our overview of how ATAD I and II are being implemented across the EU.

The UK Finance Bill provisions on the digital services tax (DST) and proposed new clauses and amendments affecting them were discussed at the Report Stage in the House of Commons yesterday, Wednesday 1 July. There were no changes agreed to the draft legislation in this area but some lively debate particularly about changes that didn’t make it into the Bill.

A collection of the brief insights throughout June 2020 of the type provided on an ad hoc basis in our Latest digital tax byte update. This edition includes the Finance Bill Committee's debates on the UK digital services tax (DST), an update on Kenya's DST/ significant economic presence (SEP) measure and an announcement that the US is beginning investigations into whether the UK's DST and various others are unfair or discriminatory toward US commerce.

The Finance Bill Committee debated the Finance Bill provisions covering the UK Digital Services Tax on Thursday 11 June. An amendment that would require the Government to report on the DST annually was defeated and a new clause to require a Government assessment of the effect on tax revenues of the DST within a short time of its introduction was not moved to a vote.

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. COVID-19 related measures continue to dominate the news, but other highlights include Digital Services Tax and EU MDR developments.

Businesses are increasingly having to consider their potential liability to UK digital service tax (DST) and developments in other territories' DSTs, all in the context of the wider OECD-led project seeking an Inclusive Framework consensus. Read our latest flyer below that highlights these challenges. To discuss any aspect of the digital taxation changes, DST or OECD options, and to see how we can support you, please contact any of the people listed on the flyer or your usual PwC advisor.

The G20/OECD Inclusive Framework of nearly 140 countries is committed to delivering change in 2020. Increasingly, countries are taking unilateral action to introduce new taxes where users/consumers are located. These taxes increase the urgency for agreement of fundamental changes to the entire international corporate tax system; allocating profit to markets and ensuring minimum levels of tax are paid.

A collection of the brief insights throughout [Month yr] of the type provided on an ad hoc basis in our Latest digital tax byte update. This edition includes summaries of the presentations on digitalisation from the OECD in its latest Tax Talks webcast of 4 May 2020 and provides some recent updates on the UK and other digital services taxes (DSTs) around the world (Czech Republic and Kenya).

A collection of the brief insights throughout April 2020 of the type provided on an ad hoc basis in our Latest digital tax byte update. This edition includes the release of further guidance from HMRC concerning compliance with the UK DST regime, as it came into force from 1 April 2020.

French tax authorities recently released tax guidelines for the digital services tax (DST) enacted in July 2019. The 3% DST applies to companies that provide certain digital services localized in France with global annual revenue exceeding EUR 750M of taxable services and exceeding EUR 25M in France. The tax is based on the amount, excluding VAT, that the taxpayer collects as consideration for taxable services provided in France since January 1, 2019. The Guidelines are open for public consultation and comments until May 23, 2020.

The Finance Bill published in March 2020, included revised draft legislation for a digital services tax (DST) to begin from 1 April 2020. A series of explanatory notes and guidance materials have also been published up to and including 1 April. Two notable differences from the draft legislation published in July 2019 are a revised scope for the definition of a marketplace and the reference in each case to services rather than platforms.

A collection of the brief insights throughout March 2020 of the type provided on an ad hoc basis in our Latest digital tax byte update. This edition includes the release of the UK Budget, confirming the intention to go ahead with a Digital Services Tax (DST) and the subsequent publication of the Finance Bill and revised guidance, plus an OECD press release confirming the July target date on the digitalisation/ globalisation project (which, given the near impossibility of physical travel following Covid-19 measures, means that innovative ways for businesses to feed into the process will be paramount).

The Indian Finance Minister presented the Union Budget 2020 on February 1. Both houses of the Indian Parliament have now passed the Budget, and it obtained Presidential assent on March 27. It will become law effective April 1, 2020. This insight highlights some key changes made to the Budget (over the original proposals).

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. This issue includes the UK Budget and Finance Bill 2020 and responding to the business impacts of COVID-19.

Charlotte Richardson, our International Tax Partner, shares her views.

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. This issue includes: 1) Budget 2020 predictions; 2) a video where our experts discuss the implications now HMRC has commenced various actions to effect recovery of the alleged state aid in the FCPE case; 3) a podcast on the key areas of the OECD’s final paper on the transfer pricing aspects of financial transactions.

A collection of the brief insights throughout February 2020 of the type provided on an ad hoc basis in our Latest digital tax byte update. This edition includes the release by the OECD on 31 January 2020 of materials agreed by the Inclusive Framework (IF), comments made in a Tax Talks webcast later the same day and a further webcast on 13 February on the impacts assessments of various of the proposals. The African Tax Administration Forum (ATAF) has also issued a subsequent Technical Note on the latest IF position. There is too comment on Significant Economic Presence (SEP) rules in two countries: the Indian draft budget for 2020-21 deferring application to April 2022 and changing withholding taxes on e-commerce activities; and Nigeria's enactment and gazetting of new measures.

A collection of the brief insights throughout [Month yr] of the type provided on an ad hoc basis in our Latest digital tax byte update. This edition includes comment on the US Trade Representative hearings and comments on French digital services tax (DST) having closed, France and US appearing to have reached a standstill on collection of DST and tariffs as well as Canada becoming more reticent on a DST while Latvia & Norway have been assessing revenue potential

2020 started with new digital services taxes (DSTs) coming into effect in Italy and Austria, with more on the horizon in the coming months, including agreed legislative provisions from Turkey beginning in March. The pace of countries considering DSTs continues to accelerate, even as discussions by the OECD Inclusive Framework move forward, driven in part to mitigate the rationale for DST implementation.

Italy recently adopted Law n. 160 of 2019, implementing its Budget Law for 2020. The adoption follows the approval of the Law on December 27, 2019, and the Law’s publication in the Official Gazette on December 30, 2019. The Law contains several corporate tax provisions, including a digital services tax and reintroduction of a notional interest deduction for capital injection.

Happy New Year and welcome to the first update on recent developments in international and treasury tax of interest to multinationals operating in the UK for 2020. This issue includes the Government's announcement of the next Budget; our publication that provides a high-level overview of the implementation of the EU Anti-Tax Avoidance Directive (ATAD) in 28 Member States; the latest edition of our global newsletter International Tax News that includes items on Colombia's tax bill that would mitigate the repeal of previous tax reform efforts and Italy’s draft 2020 budget.

A collection of the brief insights throughout December 2019 of the type provided on an ad hoc basis in our Latest digital tax byte update. This edition covers the published responses to the OECD consultation on Pillar 2 (minimum tax) and the US Trade Representative's office initial response to French DST and request for comments ahead of a public hearing starting 7 January 2020.

The G20/OECD Inclusive Framework of more than 130 countries has been reviewing the rules of the international corporate income tax system. The project which started out as 'tax and digital' has now broadened into a more thorough review of the system. Here we summarise in an easy to read two-page document, the areas in which the legislation may change, the time line, myth busters, the impact for businesses and how PwC can help.

PwC submitted a comment letter on December 3 regarding the OECD Secretariat’s consultation document on the Global Anti-Base Erosion (GloBE) Proposal under Pillar Two.

A collection of the brief insights throughout November 2019 of the type provided on an ad hoc basis in our Latest digital tax byte update. The edition includes the OECD Secretariat seeking input on global minimum tax design under Pillar 2 on digitalisation, the possible expiration of the WTO's customs duty moratorium on e-commerce and our response to the Pillar 1 'Unified Approach' consultation (along with access to the other 300+).

A collection of the brief insights throughout October 2019 of the type provided on an ad hoc basis in our Latest digital tax byte update. This includes a summary of the OECD's Secretariat Proposal for a “Unified Approach” under Pillar One of the Work Programme on digitalisation of the economy that, if ultimately agreed, would fundamentally alter the international tax regime

The 2020 Italian draft budget (Draft Budget) introduces a 3% unilateral ‘Digital Services Tax’ (DST). The DST will apply beginning January 1, 2020. The Italian government expects the DST to generate roughly 708 million EUR in tax revenue per year. Although it does not contain any specific references, the Italian DST is structured similarly to the recently introduced French DST and the European Commission’s proposal (2018/0073 (CNS) - Proposal for a Council Directive on the common system of a digital services tax on revenues resulting from the provision of certain digital services).

PwC submitted a comment letter on November 12 regarding the OECD Secretariat’s consultation paper on the unified approach under Pillar 1 of the Work Programme on the Tax Challenges of the Digitalisation of the Economy.

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. This issue includes the OECD's latest public consultation on the digitalisation of the economy, seeking views on the introduction of common global minimum tax rules, also known as Pillar Two; and the latest edition of our DAC6 Pulse newsletter, enabling you to see how EU MDR is being implemented across the EU.

The Organisation for Economic Co-operation and Development Secretariat on 8 November, published Public consultation document: Global Anti-Base Erosion Proposal (‘GloBE’) (Pillar Two) which seeks stakeholders’ views on the introduction of common global minimum tax rules across the more than 130 countries participating in the OECD Inclusive Framework.

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. This issue includes details of the latest countries implementing the EU MDR rules (DAC6), as well as the latest edition of our global newsletter International Tax News.

Please find our published October 2018 edition of Keeping up With Tax for Insurance.

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. This issue includes the latest announcements from the OECD relating to the taxation of the digitalised economy, also known as BEPS 2.0.

On 9 October, the Secretariat of the Organisation for Economic Co-operation and Development (OECD) published Secretariat Proposal for a “Unified Approach” under Pillar One that, if ultimately agreed, would fundamentally alter the international tax regime.

A collection of the brief insights throughout September 2019 of the type provided on an ad hoc basis in our Latest digital tax byte update. This includes an OECD update on Tax and Digitalisation at the IFA Congress and the Czech Republic DST bill being introduced into Parliament.

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. This issue includes our analysis of the recent judgments in the Starbucks and Fiat State aid cases, plus details of the Dutch budget, including the measures in response to the Danish beneficial ownership cases.

In this podcast Isabel Verlinden (PwC’s Global Transfer Pricing Leader), Andrea Lee (Head of Controlling and Transfer Pricing, Erste Group), and Gaby Bes, (Transfer Pricing Partner and ITS Leader, Amsterdam) discuss the issues impacting transfer pricing, including geopolitical developments, controversy, country-by-country reporting and digitalisation.

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. This issue includes articles on Brexit and the proposed update and expansion of Ireland's transfer pricing rules.

A collection of the brief insights throughout August 2019 of the type provided on an ad hoc basis in our Latest digital tax byte update. This includes the BIAC letter to Martin Kreienbaum (Chair of the Steering Group of the OECD Inclusive Framework).

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. In this issue our specialists discuss: 1) HMRC's Profit Diversion Compliance Facility, 2) legislative proposals in Luxembourg and the Netherlands to implement EU MDR, and 3) draft legislation being introduced in Luxembourg regarding ATAD2.

A collection of the brief insights throughout July 2019 of the type provided on an ad hoc basis in our Latest digital tax byte update. This includes the French DST passed in Senate, US considering response, and UK releasing draft DST legislation.

On 11 July 2019, the UK tax authorities published draft legislation and draft guidance for a digital services tax (DST) to begin from 1 April 2020. These are available for public consultation until 5 September 2019. Here we examine the draft law, and potential implications for in-scope businesses.

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. Among the items featured is the draft legislation for inclusion in Finance Bill 2019-20 that's been published for consultation and includes material relating to the Digital Services Tax (DST), the deferral of corporation tax payments on EU group asset transfers and rules for spreading transitional adjustments on new lease accounting.

The Government has published draft legislation for consultation, in preparation for the publication of the Finance Bill following Budget 2019 (expected in November). The intention is that the Finance Bill will receive Royal Assent prior to 1 April 2020, with some of the measures therefore expected to take effect on that date. This consultation period will close on 5 September. This insight shares items of particular interest from an international tax and treasury perspective.

The government is today (11 July 2019) publishing draft legislation for the next Finance Bill, including provision for a Digital Services Tax which will apply from April 2020.

Welcome to our latest update on recent developments in international and treasury tax of interest to multinationals operating in the UK. Highlights include: 1) details of our upcoming webexes on DAC6 (8 July), the Indian Budget 2019 (9 July) and Engaging with Tax Authorities (11 July).

Welcome to our latest round-up on recent international transfer pricing developments.

A collection of the brief insights throughout May 2019 of the type provided on an ad hoc basis in our Latest digital tax byte update. This includes G20 Leaders welcoming OECD progress and issuing the Osaka Declaration on the Digital Economy and the New Zealand Government consulting on a Digital Services Tax.

The OECD released on 31 May 2019 the Programme of Work to Develop a Consensus Solution to the Tax Challenges Arising from the Digitalisation of the Economy, agreed by the OECD/G20 Inclusive Framework (IF). The aims are broadly to have a political agreement on a unified approach by the end of 2019 and to be prepared to implement that solution by the end of 2020. Stakeholders at the US Council for International Business (USCIB) 2019 OECD International Tax Conference on 3-4 June had a first opportunity to react, amid presentations from OECD and members of the IF involved in agreeing the programme. Read more in this PwC Tax Policy bulletin.

There has been some commentary about whether the Digital Services Tax (DST) is consistent with both World Trade Organization (WTO) law and WTO policy. This paper explores some of the WTO aspects that the proposed DST raises.

A collection of the brief insights throughout April 2019 of the type provided on an ad hoc basis in our Latest digital tax byte update. This includes PwC's comments on the UK's user participation proposal and our wider Pillar 1 response.

A collection of the brief insights throughout March 2019 of the type provided on an ad hoc basis in our Latest digital tax byte update. This includes Netherlands support for a minimum tax proposal, EU Finance Ministers failure to agree on a compromise DST proposal and an update on the French DST proposal.

New Zealand is to consult on the design of changes to tax rules which currently allow multinational companies in the digital services field to do business in New Zealand without paying income tax.

The French government recently launched the legislative process to introduce a tax on digital sales realised by large internet and technology companies and to partially postpone the corporate income tax rate reduction initially intended to apply as of January 1, 2019.

A collection of the brief insights throughout February 2019 of the type provided on an ad hoc basis in our Latest digital tax byte update. This includes a summary of the OECD consultation to reshape the international tax system for the digitalised age - the Pillar 1 and Pillar 2 discussions.

On 29 January, the OECD released a policy note (approved by the 127 members of its Inclusive Framework (IF)) and hosted a webcast which together outlined options that the IF will examine for addressing the tax challenges of the digitalisation of the economy.

A collection of the brief insights throughout December 2018 of the type provided on an ad hoc basis in our Latest digital tax byte update. This includes indications of a French Digital Services Tax from 1 January 2019, the EP seeking to finalise its reports on digital taxes and a France-Germany proposal to reduce the scope of an EU-wide DST.

Contrary to recent indications it appears that the EU Digital Services Tax may not exempt FS as extensively as had been hoped.

Unilateral advances on digital taxes and digital PE concepts will challenge international tax harmony and cause serious challenges - are we ready? The past year has seen our tax world manage to slowly gain ground in post-BEPS territory, but also it’s been a year in which we have witnessed the rise of revolutionary concepts attempting to lead ‘old’ taxation frameworks into the digital era.

The Spanish Minister of Finance recently announced that the government will propose to Parliament a new digital services tax (DST) that would align with the draft EU Directive presented by the European Commission (EC) on 21 March 2018. The government’s aim is for the new tax to be in force before the end of 2018.

The OECD Inclusive Framework on BEPS (‘IF’, a group of 113 countries) issued its paper Tax Challenges Arising from Digitalisation – Interim Report 2018 (the ‘Report’) on 16 March, and held a public webcast to discuss its findings. This was followed by the European Commission's (EC’s) recommendations for EU-wide adoption on similar topics, which were published on 21 March. A number of countries around the world, including within the EU, have also proposed or adopted unilateral measures in recent months.

A tax issue which is relevant on a worldwide scale ideally needs a worldwide solution; however, at present, as with other areas outside of tax, the worldwide stage seem more divided than ever on future plans for a digital services tax. We look at the current state of play for the overall OECD agreement and some of the key players (UK, EU and US) feeding into the discussions and what businesses should be doing to engage with these changes and prepare themselves.