Countries have agreed to a “transitional safe harbor” that could temporarily protect US companies’ US income from other governments’ application of the global minimum tax.
The measure released Monday could help alleviate the heated political tensions in the US over a consequence of the 15% global minimum tax, known as Pillar Two. Under the undertaxed profits rule or UTPR, a US multinational could see other governments apply extra tax to its US income if it’s paying lower than a 15% effective tax rate in the US—for example, because it took certain tax credits.
“If U.S. politicians are going to legislate ...
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