Tax neutrality and Distribution Regimes

Abstract

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his chapter examines special tax regimes such as tax neutrality and Distribution Regimes and the application of the minimum tax rule under the GloBE Rules. It begins by looking at the Ultimate Parent Entity (UPE), which is a Flow-through Entity. It then considers UPEs that are subject to deductible dividend regimes, and units of the group that are subject to eligible tax systems. It concludes by considering investment entities.