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By Emilien LEBAS, Associate Partner, KPMG *
On 22 December 2017, President Trump signed into law H.R. 1, originally known as the Tax Cuts and Jobs Act. The US tax reform makes fundamental changes to the taxation of multinational entities. As we have discussed the deemed repatriation and related one-time transition tax previously, in this article we focus on another aspect of the US tax reform — the new minimum tax on global intangible low-taxed income (GILTI). GILTI is also nicknamed the ‘stick’ by opposition to the ‘carrot’, namely the foreign derived intangible income (FDII) regime(1). The impact of GILTI on Luxembourg is expected to be significant as a large number of US multinationals have subsidiaries in the country.
Background...
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