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Cross-border Tax Talks cover image

US Guidance Update: Pillar Two and more

Cross-border Tax Talks

NOTE

Preventing Circularity in Taxation for Minority Shareholders

Efforts are made to prevent circularity in taxation by ensuring that the inclusion percentage, which determines the portion of tested income subject to tax, is at 100%. If the inclusion percentage falls below 100% due to tested losses or deductions, circularity persists. This approach aims to address the complexity of taxation, particularly for minority shareholders.

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