U.S. Backs 15% Global Minimum Tax to Curb Profit Shifting Overseas

The Biden government proposed a global tax on multinational corporations of at least 15 percent in the latest round of international tax negotiations, Treasury officials said Thursday, as the US tries to reach a deal with countries fearing an interest rate hike Discourages investment.

The rate was a sub-expectation from the United States, and the Treasury Department hailed its positive reception among other countries as a breakthrough in the negotiations. The fate of the talks is closely tied to the Biden administration’s plans to revise corporate tax law in the United States, and the White House is pushing for an international deal this summer and passing laws later this year.

President Biden has proposed raising the corporate tax rate in the US from 21 percent to 28 percent, which is higher than in many other countries. A global minimum tax agreement would better enable the United States to make the increase without penalizing American companies or encouraging them to relocate overseas.

The Treasury Department held meetings this week with a group of negotiators from 24 countries on what is known as the global minimum tax that would apply to multinational companies regardless of where they are headquartered.

“The Treasury Department underlined that 15 percent is a lower limit and that discussions should continue to be ambitious and increase that rate,” the Treasury Department said in a statement after the meetings.

The global minimum tax negotiations are part of a wider global struggle to tax technology companies. They come because the Biden government is trying to put provisions in tax legislation that incentivize the relocation of jobs overseas. Talks dragged on for more than two years, slowed by the discontent of the Trump administration and the onslaught of the pandemic.

As part of its American employment plan, the von Biden administration asked for a tax known as global low intangible tax income (GILTI) to be doubled to 21 percent, which would narrow the gap between corporate payments for overseas profits and payments for profits earned Income in the United States. Under the plan, the tax would be calculated on a country basis, which would result in more overseas income being subject to tax than under the current system.

If the global minimum tax rate of 15 percent is adopted, there will still be a gap between that rate and the US domestic rate proposed by the Biden administration. Tax officials have argued that the new gap would be smaller than the current one and therefore would not affect the competitiveness of American businesses. A large delta between the global minimum tax and what US companies have to do with their overseas income gives companies based outside the US an advantage.

American corporations have closely watched the various moving parts of the negotiation. Large corporations have generally been wary of the Biden government’s tax plans.

This week Treasury Secretary Janet L. Yellen told the US Chamber of Commerce that they would benefit from the Biden administration’s proposals.

“We are confident that the investments and tax proposals contained as a package in the employment plan will improve the net profitability of our companies and improve their global competitiveness,” she said.

Immediately after her presentation, Suzanne Clark, the Chamber’s managing director, said that she disagreed.

Conclusion of an agreement on the global minimum tax will not be easy, even if an agreement is in principle close.

Finance ministers from France and Germany announced last month that they were ready to support 21 percent. However, countries have to change their laws to formally implement the agreement, and enforcement of the agreement becomes complicated. Ireland, which is not a member of the steering committee negotiating the Organization for Economic Co-operation and Development, has a corporate tax rate of 12.5 percent and has expressed reservations about such an arrangement. The British Chancellor of the Exchequer Rishi Sunak was also skeptical this week.

Manal Corwin, a former Treasury Department official in the Obama administration who now heads KPMG’s national tax practice in Washington, said other countries felt that the United States was imposed on a minimum global tax of 21 percent, which the United States said Tax would be the same as the rate proposed by the Biden government on the foreign income of US companies. The fact that the US is ready to negotiate at a lower rate is important, she said.

“In order to get a deal, it was important for the US to clarify that they didn’t necessarily say 21 percent or nothing,” Ms. Corwin said.

Still, she added, the 15 percent floor may be too high for some countries to accept and too low for some members of Congress in the United States to approve.

Rohit Kumar, head of PwC’s Washington office for national tax services, said Ireland and other countries’ response to the proposal will be crucial as a tax deal reached through the negotiations would be far from ironic.

“Are countries actually changing and enacting national law? Or is it just a political agreement where everyone says, “This is nice, but we don’t?” Said Mr. Kumar, a former top aide to Senator Mitch McConnell, the Senate minority leader. “As US lawmakers are considering these proposals, this is billions of dollars question.”

Tax officials said they never insisted on the 21 percent rate, but that they believed other countries would be receptive to the idea of ​​adopting a rate higher than 15 percent, depending on the fate of the changes to the US tax system that were introduced in To be considered.

Ms. Yellen has warned that a global “race to the bottom” has devoured government revenues and has taken a more cooperative approach to the negotiations than the Trump-appointed administration.

She is expected to continue talks on global tax reform with her international counterparts at the Group of 7 Finance Ministers meeting next month.

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