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Foreign Tax Credits and the Pillar Two GloBE Rules

Foreign tax credits interact with the Pillar Two GloBE Rules in a number of ways. In this article we assess the key impact, including:

  • Top-Up Tax and foreign tax credits
  • Substitute Loss Carry-Forwards
  • Deferred tax implications of foreign tax credits
  • The impact of foreign tax credits on the allocation to permanent establishments.

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Lee Hadnum

Lee Hadnum

Lee is a qualified Chartered Accountant and Chartered Tax Adviser. A former Senior Tax Analyst at Bloomberg Tax, Lee began his career in Ernst & Young's Entrepreneurial Services department and has 20 years of international tax planning experience. Lee's books have been recommended by The Times, The Guardian and The Telegraph.

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