Fabrizio Lolliri, Managing Director and Global Head of Transfer Pricing with Alvarez & Marsal Taxand LLC, spoke to Law360 about minimum corporate taxation and the key questions countries should consider as G-7 finance ministers work towards a final agreement.

"There is a need for clarity on how other incentives might be taken into account in calculating the extra tax due, if any," said Lolliri while discussing how countries will implement the deal. “For developing countries, where the majority of businesses are likely to be subsidiaries of larger groups and not principal entities — that is, key value drivers — those jurisdictions might find direct measures, such as withholding taxes, more efficient to attract tax revenue,” he said.

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