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'Tax and Digital flyer' summarising the OECD project

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.

Latest digital tax byte

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 information on the US Trade Representative's office investigation into the French DST and our response (along with about 200 others) to the Pillar 2 GloBE minimum tax consultation.

Digital tax megabyte for November 2019

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+).

Digital tax megabyte for October 2019

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

Italy draft 2020 budget calls for unilateral digital services tax

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).

International tax update for multinationals operating in the UK - period to 14 November 2019

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.

OECD Secretariat seeks input on global minimum tax design

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.

International tax update for multinationals operating in the UK - period to 26 September 2019

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.

International tax update for multinationals operating in the UK - period to 14 August 2019

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.

International tax update for multinationals operating in the UK - period to 18 July 2019

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.

Finance Bill 2019-20: International tax & treasury measures amongst the draft legislation published 11 July 2019

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.

OECD work programme for reaching consensus on tax challenges from digitalisation sets ambitious targets according to stakeholders

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.

Digital tax megabyte for March 2019

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.

Digital tax megabyte for February 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.

Digital tax megabyte for December 2018

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.

Keeping the PEace - The (re)Emergence of Unilateral PE Measures in wake of Multilateral Efforts

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.

Digital Services Tax - agree to disagree?

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.

Spain proposes a digital services tax

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.

OECD and EC release disparate recommendations on tax and the digitalisation of the economy

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.