International Tax Bytes by Steve Towers

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International Tax Bytes by Steve Towers International Tax Bytes by Steve Towers video podcasts provide a weekly review of the significant international tax developments impacting multinationals.

The OECD has released new peer review reports on tax transparency and the exchange of information on request. The report...
20/11/2025

The OECD has released new peer review reports on tax transparency and the exchange of information on request. The reports cover 3 jurisdictions: Eswatini, Jordan, and Vietnam.

For more information on the OECD’s new peer review reports, please log in to our website (www.itbstevetowers.com) or app.

You can sign up for our 14-day free trial by emailing us at [email protected]. Or if you are interested in our subscription plans, please go to https://www.itbstevetowers.com/registration-public/.

What is ITB? https://www.youtube.com/watch?v=v1QxrNvrYG4
Twitter: https://twitter.com/intltaxbytes
LinkedIn: https://www.linkedin.com/company/international-tax-bytes/
Instagram: https://www.instagram.com/itbstevetowers/
YouTube: https://www.youtube.com/channel/UCI9YInRGWvVVMgBlqQOilIg
International Tax Quiz archive: https://www.itbstevetowers.com/international-tax-quiz/

In India, the Mumbai Income Tax Appellate Tribunal has decided a case on the interaction between India’s domestic law in...
19/11/2025

In India, the Mumbai Income Tax Appellate Tribunal has decided a case on the interaction between India’s domestic law indirect share transfer provision, and the India / Singapore double tax treaty.

For more information on India’s eBay case, please log in to our website (www.itbstevetowers.com) or app.

You can sign up for our 14-day free trial by emailing us at [email protected]. Or if you are interested in our subscription plans, please go to https://www.itbstevetowers.com/registration-public/.

What is ITB? https://www.youtube.com/watch?v=v1QxrNvrYG4
Twitter: https://twitter.com/intltaxbytes
LinkedIn: https://www.linkedin.com/company/international-tax-bytes/
Instagram: https://www.instagram.com/itbstevetowers/
YouTube: https://www.youtube.com/channel/UCI9YInRGWvVVMgBlqQOilIg
International Tax Quiz archive: https://www.itbstevetowers.com/international-tax-quiz/

In Hungary, the Minister of National Economy has proposed a significant increase in the extra profit tax which is impose...
18/11/2025

In Hungary, the Minister of National Economy has proposed a significant increase in the extra profit tax which is imposed on banks. And in Lithuania, the parliament is considering amendments which would increase the supplementary tax rate on banks and credit institutions from 5% to 10%.

For more information on the increased tax in Hungary and Lithuania, please log in to our website (www.itbstevetowers.com) or app.

You can sign up for our 14-day free trial by emailing us at [email protected]. Or if you are interested in our subscription plans, please go to https://www.itbstevetowers.com/registration-public/.

What is ITB? https://www.youtube.com/watch?v=v1QxrNvrYG4
Twitter: https://twitter.com/intltaxbytes
LinkedIn: https://www.linkedin.com/company/international-tax-bytes/
Instagram: https://www.instagram.com/itbstevetowers/
YouTube: https://www.youtube.com/channel/UCI9YInRGWvVVMgBlqQOilIg
International Tax Quiz archive: https://www.itbstevetowers.com/international-tax-quiz/

In Brazil, Congress has passed a bill which imposes a 10% dividend withholding tax and makes significant changes to indi...
17/11/2025

In Brazil, Congress has passed a bill which imposes a 10% dividend withholding tax and makes significant changes to individual taxation, to be effective 1 January 2026.

For more information on Brazil’s bill on the dividend withholding tax, please log in to our website (www.itbstevetowers.com) or app.

You can sign up for our 14-day free trial by emailing us at [email protected]. Or if you are interested in our subscription plans, please go to https://www.itbstevetowers.com/registration-public/.

What is ITB? https://www.youtube.com/watch?v=v1QxrNvrYG4
Twitter: https://twitter.com/intltaxbytes
LinkedIn: https://www.linkedin.com/company/international-tax-bytes/
Instagram: https://www.instagram.com/itbstevetowers/
YouTube: https://www.youtube.com/channel/UCI9YInRGWvVVMgBlqQOilIg
International Tax Quiz archive: https://www.itbstevetowers.com/international-tax-quiz/

This week’s International Tax Bytes video podcast:- Brazil imposes 10% dividend withholding tax.- Banks are targeted in ...
14/11/2025

This week’s International Tax Bytes video podcast:

- Brazil imposes 10% dividend withholding tax.

- Banks are targeted in Hungary and Lithuania.

- 2 international tax cases: (1) eBay (Interaction between India’s domestic law indirect share transfer provision and the India / Singapore double tax treaty) (India); and (2) Grupo Massimo Dutti (Determining the customs value for goods which are sold in successive transactions) (ECJ).

- Other developments concerning EU, OECD, ATAF, Australia, Hong Kong, Japan, Malaysia, New Zealand, Singapore, Vietnam, Finland, Germany, Lithuania, Netherlands, UK, Liberia, Nigeria, South Africa, US, and treaties.

www.itbstevetowers.com

XCo is a Constituent Entity located in Country X where a 10% CIT rate applies. YCo is a Constituent Entity of the same M...
13/11/2025

XCo is a Constituent Entity located in Country X where a 10% CIT rate applies.

YCo is a Constituent Entity of the same MNE Group located in Country Y where a 30% CIT rate applies.

Prior to the transaction described below, the ETR of Country X for the MNE Group is 10% and for Country B is 30%.

XCo issues an interest-bearing instrument to YCo in exchange for cash (i.e., XCo borrows from YCo), that is treated as debt for financial accounting purposes, and also as debt for tax purposes in both Country X and Country Y. At the time the instrument is issued, XCo is highly-levered and cannot deduct any additional interest expense for Country X tax purposes. YCo is also highly-levered and has carried forward previously denied interest expense deductions for Country Y tax purposes sufficient to shelter the interest income with respect to the instrument issued between YCo and XCo.

What impact does this transaction have on the GloBE Income or Loss of XCo and YCo, respectively?

Answer in tomorrow’s ITB email alert!

You can find all the ITB quizzes from here: https://lnkd.in/fwHSS4G.

If you want to have our weekly quiz delivered to your mailbox, you can subscribe our newsletter via https://lnkd.in/fJghmXF or if you want to request a free trial of ITB, you can email us at [email protected].

What is ITB? https://www.youtube.com/watch?v=v1QxrNvrYG4
Twitter: https://twitter.com/intltaxbytes
LinkedIn: https://www.linkedin.com/company/international-tax-bytes/
Instagram: https://www.instagram.com/itbstevetowers/
YouTube: https://www.youtube.com/channel/UCI9YInRGWvVVMgBlqQOilIg
International Tax Quiz archive: https://www.itbstevetowers.com/international-tax-quiz/

In the latest ITB, I discuss 2 international tax cases: Australia’s G Global case and India’s Pride Foramer case. For mo...
12/11/2025

In the latest ITB, I discuss 2 international tax cases: Australia’s G Global case and India’s Pride Foramer case.

For more information on the international tax cases, please log in to our website (www.itbstevetowers.com) or app.

You can sign up for our 14-day free trial by emailing us at [email protected]. Or if you are interested in our subscription plans, please go to https://www.itbstevetowers.com/registration-public/.

What is ITB? https://www.youtube.com/watch?v=v1QxrNvrYG4
Twitter: https://twitter.com/intltaxbytes
LinkedIn: https://www.linkedin.com/company/international-tax-bytes/
Instagram: https://www.instagram.com/itbstevetowers/
YouTube: https://www.youtube.com/channel/UCI9YInRGWvVVMgBlqQOilIg
International Tax Quiz archive: https://www.itbstevetowers.com/international-tax-quiz/

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