Читать книгу International Taxation - Adnan Islam - Страница 21

 The BEAT is an alternative minimum tax on corporations that have annual gross receipts for the three prior years of at least $500m and that make certain “base erosion” payments to foreign related parties in excess of a threshold amount.

 Base erosion payments include amounts paid or accrued to a foreign related party that are deductible against U.S. taxes, such as interest, royalties, and service fees (but do not include costs of goods sold).

 The BEAT tax rate is 5% for tax years beginning in 2018, 10% for tax years 2019 through 2025, and 12.5% for tax years beginning after 2025.

 A further base erosion provision also applies to deny a deduction for certain payments of interest and royalties to related parties either pursuant to a hybrid transaction, whereby the characterization of the payment differs between U.S. and foreign tax law, or by or to a hybrid entity (a foreign disregarded entity) where the payment is not included in income by the related party.

 Base erosion provisions are modified to clarify that dividends received by an individual from a surrogate foreign corporation as a result of an inversion transaction are not qualified dividends and, therefore, are not eligible for the lower qualified dividend rates.