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November 25, 2021
The two countries have agreed on a transition mechanism from the current equalisation levy to a global minimum tax.
February 17, 2021
U.S. Cross-border Tax Reform and the Cautionary Tale of GILTI Daniel Bunn Key Findings The U.S. joined many other developed nations in adopting territorial provisions and anti-base erosion rules as part of the 2017 tax reform. One major piece of that reform, that is not typical in other territorial systems, is a new definition of currently taxable foreign earnings, Global Intangible Low Tax Income (GILTI), which is taxed at an effective rate of 13.125 percent, with the rate set to increase afte...