INTERNATIONAL TAX PLAZA - Qualified undertaxed payment rule

Details: Published: 18 February 2022

‘Qualified undertaxed payment rule’ (‘qualified UTPR’) means a set of rules implemented in the domestic law of a jurisdiction that:

(a) is equivalent to the rules laid down in this Directive in accordance with which a jurisdiction collects its allocable share of top-up tax of an MNE group that was not charged under the IIR in respect of the low-taxed constituent entities of such group;

(b) is implemented and administered in a way that is consistent with the rules laid down in this Directive and does not allow the jurisdiction to provide any benefits that are related to those rules.

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