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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.

This website is not affiliated with or related to the OECD. We provide independent insights and analysis on the OECD Two-Pillar Solution

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