2. Int'l Tax Update Significant Developments in the Global Tax System - Andrew Seidler
Withholding Taxes and the Digital Economy Progress of Profit Split from last resort moth to method of choice; The 3% Revenues Tax is a hybrid tax: • It will have to be expressed as tax on profits otherwise treaties will not apply; • It is on gross income and so behaves like a withholding tax; • In operation it may be more like an indirect tax. Is its purpose is to pave the way for something that is better, but would have otherwise been unacceptable? CCCTB. Profit Split Digital Economy Final Model CCCTB 3% Revenues Tax Digital Economy Interim Measure
Common Consolidated Corporate Tax Base On 15 March 2018 the European Parliament approved proposals for directives for the Common Corporate Tax Base and the Common Consolidated Corporate Tax Base. The directives will initially be binding on groups with revenues exceeding EUR 750m but this threshold will be lowered reaching zero after seven years. The intended implementation date is 1 January 2020. The Common Consolidated Corporate Tax Base provides the method of consolidation and the formula for allocating the tax base of a multi-national company between Member States. The allocation formula is based on headcount, sales, data collection and assets, each having equal weight. Headcount Sales Data Collection Assets
- Page 1 and 2: Helping with tax challenges whereve
- Page 3 and 4: Overview BEPS Global Tax Reform US
- Page 5 and 6: Corporate changes Tax change Post r
- Page 7 and 8: Corporate changes Tax change Post r
- Page 9 and 10: UK Planning Considerations: NOL Lim
- Page 11 and 12: Withholding Taxes After Brexit •
- Page 13: Withholding Taxes and the Digital E
- Page 17 and 18: Digital Economy Interim Measure Exa
- Page 19 and 20: BEPS Measures: Anti-hybrid rules In
- Page 21 and 22: Anti-hybrid provisions
- Page 23 and 24: US Hybrid Counteraction The Act den
- Page 25 and 26: UK approach compared to US Type Mis
- Page 27 and 28: Interest Limitation
- Page 29 and 30: Interest deduction - comparison wit
- Page 31 and 32: Global Intangible Low Taxed Income
- Page 33 and 34: GILTI Example Calculation GILTI Cal
- Page 35 and 36: Foreign Derived Intangible Income F
- Page 37 and 38: FDII Example US Corp US sales $500
- Page 39 and 40: FDII Example Step 4: Determine Rati
- Page 41 and 42: UK Planning Considerations: FDII Pu
- Page 43 and 44: BEAT - Base Erosion Anti-Abuse Tax
- Page 45 and 46: UK Planning Considerations: BEAT In
- Page 47 and 48: Brexit Monitor Visit https://www.rs
- Page 49: THANK YOU
Withhold<strong>in</strong>g <strong>Tax</strong>es and <strong>the</strong> Digital Economy<br />
Progress of Profit Split from last resort<br />
moth to method of choice;<br />
The 3% Revenues <strong>Tax</strong> is a hybrid tax:<br />
• It will have to be expressed as tax on<br />
profits o<strong>the</strong>rwise treaties will not<br />
apply;<br />
• It is on gross <strong>in</strong>come and so behaves<br />
like a withhold<strong>in</strong>g tax;<br />
• In operation it may be more like an<br />
<strong>in</strong>direct tax.<br />
Is its purpose is to pave <strong>the</strong> way for<br />
someth<strong>in</strong>g that is better, but would have<br />
o<strong>the</strong>rwise been unacceptable? CCCTB.<br />
Profit Split<br />
Digital<br />
Economy<br />
F<strong>in</strong>al<br />
Model<br />
CCCTB<br />
3%<br />
Revenues<br />
<strong>Tax</strong><br />
Digital<br />
Economy<br />
Interim<br />
Measure
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