June 28 (Reuters) - The United States and India have
extended a standstill agreement on U.S. retaliation over India's
digital-services tax until Sunday, aligning it with a
fast-approaching deadline for a global deal to reallocate taxing
rights on the world's biggest and most profitable companies, the
U.S. Treasury said on Friday.
In a brief announcement, the Treasury said that a November
2021 political compromise that expired March 31 would be
extended through the end of the month, as negotiations on the
"Pillar 1" tax agreement continue.
The Pillar 1 deal is in danger of collapse, as the U.S.,
India and China have failed to agree on key elements of the deal
related to calculation of transfer pricing to help determine
local tax liabilities.
The stakes of the last-minute negotiations are high. The
deal's failure could prompt several countries to reinstate their
taxes on U.S. tech giants such as Apple ( AAPL ), Alphabet's
Google, and Amazon.com ( AMZN ) and risk punitive
duties on billions of dollars in exports to the U.S.
The extension of the U.S.-India agreement also aligns it
with the expiration of similar deals with six other countries
that had enacted digital-services taxes: Austria, Britain,
France, Italy, Spain and Turkey.
These countries suspended their digital-services taxes
shortly after a two-pillar tax deal was struck in October 2021
by nearly 140 countries to impose a 15% global minimum corporate
income tax and complete negotiation on reallocating some taxing
rights on large multinationals to countries where they sell
goods and services. This was meant to replace the
digital-services taxes.
At the same time, the U.S. Trade Representative's office
agreed to suspend planned trade retaliation against the digital
taxes while negotiations were completed.
U.S. negotiations are being led by the Treasury, where a
spokesperson declined to comment on the state of negotiations.
A USTR spokesperson also declined to comment on next steps,
but added: "As we've said previously, we oppose digital-services
taxes that unfairly target U.S. companies and the OECD/G20
Inclusive Framework negotiations offer the best path to address
the challenges that digitalization of the economy poses to the
international tax system."
Treasury Secretary Janet Yellen told Reuters at a G7 finance
meeting in May that India and China were hindering agreement on
the alternative transfer-pricing mechanism known as "Amount B,"
but that talks were continuing.
Italy's finance minister also blamed the U.S. demands for
the inability to agree on terms. Italy is seeking an extension
of the U.S. standstill agreement and sources told Reuters
earlier on Friday that Italy has asked Google to pay $1 billion
in unpaid taxes.