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Pillar Two: A Japanese perspective
Cross-border Tax Talks
The Japan CFC and the US CFC Regime
The CFC rules apply to all companies, whereas Pillar 2 applies to only in-scope companies. The Japan CFC net may be even broader because it's 20% and 30% effective tax rate threshold. Now what about to the extent that jurisdictions start to implement QDMTTs around the world? Any thoughts about whether that may be creditable from a Japanese perspective if we do start seeing jurisdictions implement a QDMTT starting in 2024? Sure.
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