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🌍 Global Minimum Tax – The Road Ahead
The international tax regime is facing renewed turbulence. The G7’s June 2025 “side-by-side” approach, which exempts U.S.-headquartered groups from UTPR and IIR obligations, has triggered doubts about whether the global minimum tax can truly remain “global.” Adding to the complexity, the U.S. has officially walked away from the Global Tax Deal, while the United Nations is moving towards a framework for taxing cross-border services at source.
For multinational enterprises, this translates into heightened uncertainty in international compliance.
Questions around Domestic Minimum Top-Up Taxes (DMTTs), safe-harbour provisions, and the recognition of substance-based incentives are under active debate, with regions such as the EU advancing independent measures.
For Indian corporations with cross-border operations, the key lies in agility—continuously scenario-planning and aligning tax strategies with shifting international frameworks. Stability in taxation is no longer a given; adaptability is the new imperative.
👉 At our firm, we are closely monitoring BEPS 2.0 to equip businesses with forward-looking strategies in this rapidly evolving environment. Contact us for tailored advisory on global tax risk management including implications under safe harbour and QDMTT.
#BEPS #GlobalMinimumTax #InternationalTax1. Introduction – Rising uncertainty post-BEPS 1.0 and Inclusive Framework.