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U.S. Skeptical About Permanent Safe Harbor for GLOBE Tax Framework

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Replacing the Pillar 2 UTPR With an Undertaxed Payments Rule

  • By Thomas Horst

Thomas Horst examines differences between the undertaxed payments rule and the UTPR, or undertaxed profits rule, and whether adoption of the former could resolve incongruities between the laws of the United States and the many countries that have enacted the UTPR and provide a legally acceptable alternative to the UTPR.

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