ITR Spring Issue 2023: Editorial

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2025

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

ITR Spring Issue 2023: Editorial

EU - pillar two.jpg

ITR’s latest quarterly PDF is going live today, leading on the EU’s BEFIT initiative and wider tax reforms in the bloc.

Our cover story looks at the European Commission’s work on the Business in Europe: Framework for Income Taxation initiative and what companies want to see from it. It’s crunch time for European governments to decide whether there will be an EU corporate tax system.

An EU-wide corporate tax base with its own transfer pricing (TP) rules may finally be designed this year. The European Commission has taken some old ideas like the common consolidated corporate tax base and combined them with new concepts from the OECD’s two-pillar solution.

A limited version of formulary apportionment may one day become a reality in the EU, but there are many obstacles to pass along the way. The future of the arm’s-length principle and the prospects for a global minimum corporate tax rate are at stake.

Turning abstract concepts into concrete policies is easier said than done. The OECD may have created the groundwork for BEFIT, but the Commission’s initiative could become an example of how pillars one and two should work in practice.

We have a comprehensive issue of ITR this season, covering everything from the Brazil-UK tax treaty and the tax challenges of global mobility to Indian tax disputes and the TP impact of US sanctions on China. This issue includes an analysis of the US budget proposal for 2024 and two features on the implementation of pillar two in Asia.

Meanwhile, the Supreme Court of Canada is going to hear a case brought by Dow Chemical in its bid to secure a hearing at the Tax Court of Canada. This dispute will set a crucial precedent for taxpayers.

As we get further into 2023, the pace of change in tax continues to gather momentum. The OECD may have secured a global minimum corporate rate, but taxpayers are still waiting to see if there will be a final deal on pillar one this summer.

Read the ITR Spring Issue 2023 here

more across site & shared bottom lb ros

More from across our site

Awards
Submit your nominations to this year's WIBL EMEA Awards by 6 February 2026
Defending loss situations in TP is not about denying the existence of losses but about showing, through proactive measures, that the losses reflect genuine commercial realities
Further empowerment of HMRC enforcement has been praised, but the pre-Budget OBR leak was described as ‘shambolic’
Michel Braun of WTS Digital reviews ITR’s inaugural AI in tax event, and concludes that AI will enhance, not replace, the tax professional
The report is solid and balanced as it correctly underscores the ambitious institutional redesign that Brazil has undertaken in adopting a dual VAT model, experts tell ITR
The Brazilian law firm partner warns against going independent too early, considers the weight of political pressure, and tells ITR what makes tax cool
The lessons from Ireland are clear: selective, targeted, and credible fiscal incentives can unlock supply and investment
The ITR in-house award winner delves into his dramatic novelisation of tax transformation, and declares that 'tax doesn’t need AI right now'
Recent news of job cuts at EY is symptomatic of how the PwC controversy has tarnished the reputation of the entire ‘big four’
Experts reportedly discussed extending the safe harbour to 2027 to give countries more time to legislate; in other news, Baker McKenzie and Greenberg Traurig made senior tax hires
Gift this article