Threading the Needle: Pillar Two and the IRA’s Green Energy Credits
Cross-border Tax Talks
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The Impact of Refundable Tax Credits on the FISQ
The OECD created this definition of a qualified refundable tax credit. And so really despite whether it's IFRS or GAP or whatever accounting standard, that is not ultimately determinative for purposes of pillar two. So the classic example I think that we've seen is the US R&D credit versus the UK R & D credit. That credit will reduce your ETR much more significantly for Pilla 2 purposes than if you did exactly the same activities in the UK and qualified for the UK credit.
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