International review for June

In June, tax made global headlines as the G7 reached a consensus on proposals to address the challenges of the digitisation of the economy. A global minimum tax rate of at least 15 percent was agreed. G7 finance ministers also found consensus on the allocation of global taxing rights, based on a reallocation of at least 20 percent of profit exceeding a 10 percent margin “for the largest and most profitable multinational enterprises.” Meanwhile, significant progress was also made in the EU on the public country by country reporting proposal. In other news, Brazil has been renewing its efforts to join the OECD and as part of this is understood to be looking at more fully implementing the arm’s length principle for transfer pricing; Nigeria has temporarily suspended country by country reporting obligations for many subsidiaries and branches; and Italy is bringing in an exceptional notional interest deduction for FY21.

In the latest of his regular articles for Tax Journal*, Tim Sarson looks back at some of the interesting developments that unfolded in June in the international tax arena. This article includes updates on the following:

• G7 progress on BEPS 2.0.
• EU public country by country reporting (CbCR).
• The suspension of CbCR in Nigeria for many branches and subsidiaries.
• Potential new Transfer Pricing rules in Brazil.
• Exceptional notional interest deduction in Italy.

* First published by Tax Journal on 25 June 2021. Reproduced with permission.

For further information please contact: 

• Tim Sarson