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EU Tax Working Group To Discuss Digital Tax, MNE Tax Issues

The EU's High Level Working Party (Taxation) will discuss international tax reform at its meeting today April 18.

According to its agenda, released ahead of the meeting, the working party will discuss the outcome of meetings of the OECD Task Force on the Digital Economy and the G20 meeting of finance ministers, which took place in March, and the OECD Forum of Harmful Tax Practices, which met for three days ending April 6, 2018.

Specifically, it will discuss proposals recently put forward by the EU Commission and the OECD for an interim digital tax measure – a tax on revenues from the digital economy that would otherwise go untaxed, where companies derive revenue from online users' data or activities – and their longer-term proposal for a new digital permanent establishment rule.

Next, it will discuss the EU's common corporate tax base proposal, including evaluating its potential impact on national tax revenues. This project is intended to harmonize EU member states' corporate tax regimes to enable taxation of multinational groups under a formulary apportionment approach, under which tax would be levied, and the revenues allocated to member states, based upon objective factors, such as sales and employment levels in each state. The EU Presidency is to present a progress update.

It will also discuss the state of play on the financial transaction tax, which appears to have been a non-starter for the EU. Under the proposed FTT directive drafted by the Commission in 2011, the tax would be imposed on all transactions in financial instruments, with the exchange of shares and bonds taxed at a rate of 0.1 percent and derivative contracts at a rate of 0.01 percent.

However, the participating member states (originally just 11 of the member states) have found it very difficult to arrive at a consensus on the technical details of the new directive, particularly around the issues of how the tax will apply to derivative trades, and to transactions made by pensions funds.

The Working Party is expected to also hold a "strategic discussion" on taxation of the financial sector, including with regards to value-added tax.

Finally, it will discuss tax reform options and proposals for future discussion.
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OECD Urges International Tax Reform Of Savings, Investments
by Ulrika Lomas, Tax-News, Brussels
13 April 2018

"While countries do not necessarily need to tax savings more, there is a lot of room to improve the way countries tax savings," according to Pascal Saint-Amans, Director of the OECD Centre for Tax Policy and Administration.

Launching two new reports on April 12, he said: "There is also a very strong case to be made for addressing income and wealth inequality through the tax system, notably by ensuring effective taxation of capital. Governments have an opportunity to increase both the efficiency and fairness of their tax systems, and these reports outline concrete measures to help achieve this."

The reports – Taxation of Household Savings and The Role and Design of Net Wealth Taxes - say that taxes are among the most effective tools governments have for reducing inequalities and bringing about more inclusive growth. Taxation of Household Savings provides a detailed review of the way savings are taxed in the 35 OECD countries and five key partner countries (Argentina, Bulgaria, Colombia, Lithuania and South Africa). It finds large differences within countries in the tax treatment of a range of assets, such as bank accounts, bonds, shares, private pensions, and housing, and points out that tax rules – rather than pre-tax rates of return – are likely driving some savings decisions.

According to the OECD report, differences in tax treatment of certain types of savings often favor wealthier taxpayers. For instance, poorer taxpayers tend to hold a larger share of their wealth in relatively high-taxed bank accounts than wealthier taxpayers, who tend to hold a greater share of their wealth in investment funds, pension funds, and shares, which are often taxed at lower rates.

The OECD report puts forward a range of opportunities for greater tax neutrality across different types of savings to foster more inclusive growth. The report also finds that opportunities may exist for some countries to increase progressivity in their taxation of savings as a result of the recent move towards the automatic exchange of financial account information between tax administrations.

"This ground-breaking change in the international tax environment is likely to make it harder in years to come for taxpayers to evade tax by hiding income and wealth offshore," the OECD said, "presenting a particular opportunity for countries that previously moved away from progressive taxation of capital income to reintroduce a degree of tax progressivity."

The second report – The Role and Design of Net Wealth Taxes – examines the use of net wealth taxes, both currently and historically, across the OECD. It assesses the case for and against the use of net wealth taxes to raise revenue and reduce inequality, but does not call for their introduction.

The report suggests that there is little need for net wealth taxes in countries with broad-based personal capital income taxes, including capital gains taxes, and well-designed inheritance and gift taxes. It finds there may be scope for such taxes in countries where the taxation of capital income is low or where inheritance taxes are not levied.

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