Pillar Two: A Japanese perspective
Cross-border Tax Talks
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QDMTT and CFC Income Pickup in Japan
QDMTT takes precedence over a CFC tax, according to administrative guidance. The question will be, will QDMTT be creditable in Japan or otherwise there could be a double taxation issue. If the Japanese CFC rules apply, there's going to be a CFC income pickup. So I think it's similar to US and GILTI, perhaps to the extent it will be applicable in the future.
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