Document Type
Article
Publication Date
5-2024
Abstract
Both the global intangible low-taxed income provisions of the Tax Cuts and Jobs Act and the substance-based income exclusion of pillar 2 provide incentives to shift real investment to lowtax locations. Under GILTI, a 10 percent return on tangible assets of the subsidiaries of U.S. multinationals (qualified business asset investment) is exempt from tax. Under pillar 2, the top-up tax calculation excludes 10 percent of payroll costs and 8 percent of the carrying value of tangible assets in a jurisdiction.
Recommended Citation
Avi-Yonah, Reuven S. "The Case for Targeted Location Incentives." Tax Notes International 114, no. 7 (2024): 1049-1053.
Comments
Reprinted with the permission of Tax Analysts.