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Replacing the Pillar 2 UTPR with an undertaxed payments rule by Thomas Horst

By: Horst, Thomas.
Material type: ArticleArticleSubject(s): SEGUNDO PILAR (OCDE) | TIPO MÍNIMO GLOBAL | RECURSOS | UTPR (OCDE) In: Tax Notes International v. 116, n. 12, December 23 2024, p. 1873-1877Summary: 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.
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OP 138-Bis/2024/116/12-3 (Browse shelf) Available OP 138-Bis/2024/116/12-3

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.

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