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The objective is to make certain multinational corporations do not use cross-border payments to lower their US taxes to less than 10% of an expanded definition of taxable profits.
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The bottom erosion tax demands an yearly calculation. Tax equity traders will likely not know right until the end of each year whether they must shell out back again tax credits on which they were being counting that year.
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The numerator with the fraction is thirty% in the partnership's cash flow with the 12 months, less the curiosity the partnership are unable to deduct that 12 months. The denominator is 30% from the partnership's income for the calendar year.
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