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" ... Now this is often described as being similar to the U.S. global intangible low-taxed income regime, or GILTI regime. It also includes the undertax payment rule that gives a country the ability to deny deduction or apply withholding tax, a payment tax below a minimum rate. This is sometimes described as being similar to the U.S. base erosion and antiabuse tax, or the BEAT. ... "
" ... Pillar 2 would effectively ensure global minimum taxation primarily through the global anti-base erosion or GLOBE proposal, which comprises the income inclusion rule, which has been described as being similar to the GILTI regime and the undertax payment rule, which is similar to the BEAT. Two big questions here were the minimum rate. What is the rate going to be? And how will the GILTI regime and BEAT coexist with the GLOBE regime? ... "
" ... The first is an income inclusion rule, and that's the part that's similar to GILTI. Income tax below whatever minimum threshold hasn't been agreed yet would be taxable in the ultimate parent entity's jurisdiction. This rule will be backed up by something called the undertax payments rule, which would either deny a deduction or allow taxation at source for payments that aren't taxed at this minimum threshold. There would also be something called the subject to tax rule, which would allow withholding or source-based tax for other types of payments that are not taxed at the minimum rate. ... "