Treasury recently issued Notice 2023-80 that lays the groundwork for future rulemaking, addressing the interaction between foreign tax credits and Pillar 2 rules.
The guidance touches on various aspects, such as top-up tax creditability, indirect foreign tax credits, and alterations to the non-duplication requirement. It also focuses primarily on the creditability of foreign taxes applying the GLOBE rules, including disallowing credits if U.S. income tax liability is involved. While questions remain regarding the application of the undertaxed payment rule (UTPR), Treasury plans to issue additional guidance.
In a recent Tax Notes article, "U.S. Income Analysis Complicates Pillar 2 FTC Credibility," A&M Tax Managing Director Brendan Sinnott provides key insights into the interaction between foreign tax credits and Pillar 2 rules, as well as potential implications for multinational enterprises and taxpayers.
Read the Full Article
Overview of the BMF Instruction Sheet on Cross-Border Audit Cooperation
July 24, 2025
With its updated instruction sheet on cross-border audit cooperation, the German Ministry of Finance signals a stronger focus on coordinated tax enforcement. Joint and simultaneous audits are gaining relevance – especially in transfer pricing matters. For multinational groups, this means greater pressure to ensure consistency and audit readiness across jurisdictions.
PMK 37/2025: New Indonesia Regulation on Withholding of Article 22 Income Tax by E-Commerce Platforms
July 23, 2025
Learn how PMK 37, Indonesia's new e-commerce income tax regulation, expands the tax base and modernizes tax collection procedures under Article 22.
Announcement to Delay Tariffs to August 1, 2025: Implications for Pan-Asia Region
July 23, 2025
With US tariffs set to commence on August 1, 2025, discover the implications for affected Pan-Asia countries.
Alvarez & Marsal Tax Launches Indonesia Tax Practice Led by Jaap Zwaan
July 22, 2025
Alvarez & Marsal Tax, (A&M Tax), an affiliate of leading global professional services firm Alvarez & Marsal (A&M), today announced the launch of its Indonesia tax practice, further strengthening its presence in Asia.
