Developing countries
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UN Proposal on 12A UN MC showcases UN tax dynamics
Originally published: March 2024 The UN Tax Committee will hold its 28th session today (https://lnkd.in/exJ7aD8Zhttps://lnkd.in/eixQNxTu). This committee is in charge of the UN Model Tax Convention (UN MC). Although this committee does not cover the hotly debated new general UN Tax Convention, the dynamics showcase how tax cooperation at the UN looks like. On the… Continue reading
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SC & EHEID Reports October 2023
Originally published: November 2023 Last month, the South Centre (SC) published reports where they suggested increasing source taxation ‘while seeking conformity with tax treaty rules’ (https://lnkd.in/erEXXQPU). Then, they followed up with another report (https://lnkd.in/eR7qiXWh) identifying specific problems in double tax treaty (DTT) networks and suggesting updating DTTs through a multilateral instrument (MLI). The new report focuses… Continue reading
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South Center Tax Policy Brief
Originally Published: November 2023 The UN tax committee seems to have lost buy-in from key countries before it even got started (https://lnkd.in/erFMU9mc), which I suppose was always likely. So what way forward do they still have? Last week, the South Centre (SC) published a tax policy brief on Pillar 1 (P1) that hints on an… Continue reading
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Assessing Pillar 2 alternatives for emerging markets
Originally published: August 2023 Emerging markets (EMs) often criticize the OECD and say that MNEs can erode tax base through profit shifting and the tools to fight this (eg transfer pricing) are too complicated. Although I don’t find all the critiques of the OECD all too convincing (https://lnkd.in/eg8aBdnrhttps://lnkd.in/erHK6_Amhttps://lnkd.in/e_mcihHU), the critics are right that the OECD work… Continue reading
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New York instead of Paris?
Originally published: June 2023 Yesterday, the Swiss referendum approved moving ahead with the Swiss implementation of OECD’s global minimum tax, Pillar 2 (P2). Already, here is an article by Dominik Gross (https://lnkd.in/eT2zUAWa), arguing Swiss support for P2 proves P2 is ineffective against tax havens. Gross argues that instead the UN should take over the international tax debate.… Continue reading
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UTPR+ would be a Supermassive Black Hole
Originally published: June 2023 Tax activists (https://lnkd.in/eMTuXzMQ) and developing countries (https://lnkd.in/eYk-r29Zhttps://lnkd.in/e-uGQ3Zn) often criticise the OECD Pillar 2 (P2) minimum tax rate of 15% as too low. In their view, MNEs would still profit shift for small rate tax arbitrage and P2 design (in particular QDMTT) rewards being on the receiving end of that profit shift,… Continue reading
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Pillar Two and Developing Countries: The STTR and GloBE Implementation
Originally published: September 2022 Heydon Wardell-Burrus published another analysis on Pillar 2 (https://lnkd.in/gHCvWnET), this time focusing on developing countries. He concludes that STTR can easily be avoided by both MNEs (eg back-to-back positions, moving flows) and countries (raising tax rate to 9% like the UAE is considering, having high rates but combine them with source taxation… Continue reading
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Did emerging markets get what they wanted from the OECD global tax deal?
Originally posted: October 2021 Did emerging markets get what they wanted from the OECD global tax deal? The TLDR answer is ‘no’. Here’s why. Based on my reading of media reports, their priorities were (1) easy to administer rules without a legion of specialist lawyers, (2) with more taxing rights to emerging markets (typically source… Continue reading
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Global Tax Overhaul Endorsed by 130 Nations as Deal Gets Closer
Originally posted: July 2021 Not entirely surprising, but this news reinforces the message that this deal is now quite likely to happen (although the precise contents will continue to be a matter of many political negotiations). There are a few very powerful countries (US, France particularly) who are putting a lot of weight behind this… Continue reading
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Exception to the rule? G7 deal on tax triggers carve-out talk
Originally posted: June 2021 Tons of negotiations going on the G7 tax deal, ahead of the G20 meeting in July. A few interesting things to look out for: – I have seen many arguments made on LinkedIn that minimum tax hurts the ability of emerging markets to attract FDI, but China arguing to exempt its… Continue reading
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Tax Policy: How Inclusive Is The OECD’s Inclusive Framework?
Originally posted: January 2021 Interesting discussion about the extent low income countries have power and influence outcomes in global tax policy debates. A few interesting points coming out of this discussion: – not surprisingly, there is an element of window dressing on the talk of including developing countries perspectives. It is hard for developing countries… Continue reading
About Me
I am Leonard, an experienced M&A Tax and International Tax expert. I write about tax on LinkedIn and Twitter sometimes (but mostly LinkedIn). People liked the posts, but there were too many of them to keep track of. So, now they are on a blog for future reference.
Obvious disclaimers on all my posts: this is not advice. These views are my own and do not necessarily represent my employer.
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LinkedIn profile: https://www.linkedin.com/in/leendertwagenaar/