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Searching for Pillar Two clarity: The OECD’s Administrative Guidance
Cross-border Tax Talks
The Impact of the Globe Calculation on US Taxes
US multinationals can still end up paying some US tax on guilty, even if all of the jurisdictions that they operate are 13.125 for the reason that you just mentioned because of expense and portionment. So it could really impact the numerator of the calculation depending what that globe calculation is at each of the constituents. It is meant to be a proportionate push down to the low tax jurisdictions, but if you only have one jurisdiction that is lowTaxed Costa Rica will get the entire amount of that push down. If there's no jurisdictions that are below 13.125, then those taxes stay as US taxes.
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