Foreign Tax Credits and the Pillar Two GloBE Rules
July 21, 2025
Foreign tax credits interact with the Pillar Two GloBE Rules in a number of ways. In this article we assess the key impact.
In Bermuda’s 2023 Budget last week, the government has announced it is actively looking at how to implement the Pillar Two global minimum tax and that Bermuda could reap significant revenue benefits.
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Foreign tax credits interact with the Pillar Two GloBE Rules in a number of ways. In this article we assess the key impact.
In most cases, a Qualifying Refundable Tax Credit will result in a higher Pillar Two effective tax rate than a non-qualifying tax credit. However, this is not always the case. We look at some examples in this article.
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