Horst, Thomas
Replacing the Pillar 2 UTPR with an undertaxed payments rule / by Thomas Horst
In this article, Horst examines differences between the undertaxed payments rule and the UTPR, or undertaxed profits rule, and whether adoption of the former could resolve incongruities between the laws of the United States and the many countries that have enacted the UTPR and provide a legally acceptable alternative to the UTPR.
SEGUNDO PILAR (OCDE)
TIPO MÍNIMO GLOBAL
RECURSOS
UTPR (OCDE)
Tax Notes International 1048-3306 v. 116, n. 12, December 23 2024, p. 1873-1877
Replacing the Pillar 2 UTPR with an undertaxed payments rule / by Thomas Horst
In this article, Horst examines differences between the undertaxed payments rule and the UTPR, or undertaxed profits rule, and whether adoption of the former could resolve incongruities between the laws of the United States and the many countries that have enacted the UTPR and provide a legally acceptable alternative to the UTPR.
SEGUNDO PILAR (OCDE)
TIPO MÍNIMO GLOBAL
RECURSOS
UTPR (OCDE)
Tax Notes International 1048-3306 v. 116, n. 12, December 23 2024, p. 1873-1877