Replacing the Pillar 2 UTPR with an undertaxed payments rule by Thomas Horst
By: Horst, Thomas
.
Material type: 
ArticleSubject(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.
| Item type | Current location | Home library | Call number | Status | Date due | Barcode |
|---|---|---|---|---|---|---|
| Artículos | IEF | IEF | OP 138-Bis/2024/116/12-3 (Browse shelf) | Available | OP 138-Bis/2024/116/12-3 |
Browsing IEF Shelves Close shelf browser
| No cover image available | No cover image available | No cover image available | No cover image available | No cover image available | No cover image available | No cover image available | ||
| OP 138-Bis/2024/116/1-2 Final digital asset reporting regulations alleviate brokers’ obligations | OP 138-Bis/2024/116/12-1 Does Pillar 2 qualify transparent entities and PEs as residents under tax treaties? | OP 138-Bis/2024/116/12-2 Reasserting U.S. tax leadership, starting with amount B | OP 138-Bis/2024/116/12-3 Replacing the Pillar 2 UTPR with an undertaxed payments rule | OP 138-Bis/2024/116/12-4 Revising the transfer pricing regulations’ reliability provisions | OP 138-Bis/2024/116/1-3 Understanding foreign trust reporting penalty assessment | OP 138-Bis/2024/116/1-4 Video game downloadable content in tax treaties |
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.
There are no comments for this item.