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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