EU Tax Commissioner, Paolo Gentiloni, has described the US proposal for a corporate alternative minimum tax (CAMT) as a ‘positive and interesting decision … that establishes a minimum of 15 per cent corporate taxation in the US’ but which is ‘not a substitute for the implementation of Pillar 2’.
Welcoming the development in the US, Gentiloni noted that agreement in the Senate was reached on a 51:50 basis so was ‘not a bipartisan decision’, and that CAMT does not fulfil or implement the requirements for Pillar 2.
Although CAMT is a 15% tax on corporate profits, unlike Pillar 2 it does not require taxation on a country-by-country basis – a potential stumbling block along the road to implementation of Pillar 2.
Notwithstanding objections from Hungary, Gentiloni expects discussions to continue between EU member states on implementation of Pillar 2, with the possibility of a number of states looking to implement the proposals through ‘enhanced co-operation’ which would allow those states to proceed without others who do not wish to participate.
EU Tax Commissioner, Paolo Gentiloni, has described the US proposal for a corporate alternative minimum tax (CAMT) as a ‘positive and interesting decision … that establishes a minimum of 15 per cent corporate taxation in the US’ but which is ‘not a substitute for the implementation of Pillar 2’.
Welcoming the development in the US, Gentiloni noted that agreement in the Senate was reached on a 51:50 basis so was ‘not a bipartisan decision’, and that CAMT does not fulfil or implement the requirements for Pillar 2.
Although CAMT is a 15% tax on corporate profits, unlike Pillar 2 it does not require taxation on a country-by-country basis – a potential stumbling block along the road to implementation of Pillar 2.
Notwithstanding objections from Hungary, Gentiloni expects discussions to continue between EU member states on implementation of Pillar 2, with the possibility of a number of states looking to implement the proposals through ‘enhanced co-operation’ which would allow those states to proceed without others who do not wish to participate.
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