European Direct Tax

The European Direct Tax Committee covers income-based tax aspects of European operations, including tax treaty matters, and develops the Institute’s positions and submissions to taxing authorities in European countries, as well as the European Union and OECD.

TEI Comments on the OECD’s “GloBE” Proposal

On December 2, TEI filed comments responding to the OECD’s public consultation document entitled Global Anti-Base Erosion Proposal (“GloBE”) – Pillar Two, focusing on the need for states to withdraw unilateral measures, a strong binding dispute resolution mechanism, and clear ordering rules, among other things.

TEI Files Comments regarding the OECD Secretariat’s “Unified Approach” to Pillar One

On November 11, TEI submitted comments to the OECD Secretariat regarding its proposed “unified approach” to “Pillar One” of the tax challenges of the digitalization of the economy. TEI’s comments focused on the need for (i) the withdrawal of unilateral measures after a multilateral agreement, (ii) a multilateral dispute resolution mechanism; and (iii) reliance on taxpayer consolidated financial statements for purposes of the approach, among other subjects.

TEI Files Comments regarding the Platform for Collaboration on Tax’s Draft Transfer Pricing Toolkit

On November 7, TEI submitted comments to the Platform for Collaboration on Tax – a joint initiative of the World Bank, OECD, International Monetary Fund, and United Nations – regarding its draft transfer pricing documentation toolkit for developing countries.

TEI Submits Comments to the OECD regarding Digitalization of the Economy Consultation

On March 4th, TEI submitted comments to the OECD regarding its public consultation document entitled Addressing the Tax Challenges of the Digitalisation of the Economy. TEI will also participate in in the upcoming public consultation on March 13-14 in Paris.

TEI Submits Comments to the Australian Treasury regarding Digital Economy Discussion Paper

On November 29th, TEI submitted comments to the Australian Treasury regarding its Discussion Paper on the digital economy and Australia’s corporate tax system.

TEI Submits Comments to the OECD regarding the Transfer Pricing aspects of Financial Transactions

On September 6th, TEI submitted comments to the OECD regarding its public discussion draft under BEPS Actions 8-10 on the transfer pricing aspects of financial transactions.

TEI Comments on Scope of Revisions to OECD Transfer Pricing Guidelines

On June 19, TEI submitted comments to the OECD regarding the scope of future revisions to Chapters IV and VII of the OECD’s transfer pricing guidelines. TEI’s comments focused on the practical aspects of any future guidance.

TEI Comments on the European Commission’s Digital Economy Tax Proposals

On May 15, TEI submitted comments regarding the European Commission’s proposals to define the concept of a “significant digital presence” for corporate income tax purposes and impose an interim digital services tax.

TEI Comments on European Commission Digital Economy Survey

On January 2, TEI submitted responses to the European Commission’s survey regarding “fair taxation of the digital economy,” disagreeing with the Commission’s proposed alternatives to taxing digital commerce.

TEI Comments on Taxation of Offshore Indirect Transfer

On October 19, TEI submitted comments to the Platform for Collaboration on Tax regarding the Platform’s draft toolkit on the taxation of offshore indirect transfers.
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