Senate Ratifies Several Stalled Tax Treaty Protocols

August 2019

Summary

Recently, the United States Senate approved the ratification of stalled protocols amending tax treaties with Luxembourg, Switzerland, Japan and Spain. New income tax treaties with Hungary, Chile and Poland, however, have still not been approved, partially due to concerns regarding the interaction of these treaties with Section 59A, Tax on base erosion payments of taxpayers with substantial gross receipts.
 
The protocols to amend the treaties were signed several years ago, but the ratification of the four protocols was stalled due to objections by Senator Rand Paul regarding taxpayer privacy concerns.
 
The protocols will enter into force once certain additional steps are taken by the United States and the treaty partner country. 
 

BDO Insight

Taxpayers should review how the changes made by the protocols could potentially impact their business operations. Please contact a BDO International Tax Specialist if you would like more information regarding the protocols discussed above.
 

CONTACTS
 
Joe Calianno
Partner & International Tax Technical Practice Leader, National Tax Office
  Monika Loving
Partner & International Tax Practice Leader

 
Brandon Boyle
Principal
  Reese Fredrickson
Partner

 
Annie Lee
Partner
  Chip Morgan
Partner

 
Robert Pedersen
Partner
  Jerry Seade
Principal

 
Natallia Shapel
Partner
  Sean Dokko
Managing Director, National Tax Office