Qualifying Domestic Minimum Top-Up Tax – oecdpillars.com
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One key difference between a QDMTT and the standard Global Minimum Tax (eg the IIR and UTPR) is that CFC taxes are not included in the QDMTT ETR but they are included in the GloBE ETR. This could therefore lead to a lower QDMTT ETR and higher top-up tax.
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