USA: OFFSHORE PROFITS REDUCTION

On 22^th December 2017 the American tax reform was approved, decided by the USA President, with the aim to end the operations that allowed the companies to use foreign tax credits in order  to limit the american taxation.

With the implementation of the reform and in accordance with the prohibition of double taxation, companies are now allowed to access a foreign tax credit (FTC) in order to balance the amount paid in American taxes with the amount of taxes due in the country where the profits were obtained.

Furthermore, to fight the transfer of offshore profits, a minimum tax on Intangible Global Low Tax Income (GILTI) was introduced.

Our staff is available for any clarifications.