New US tax reform
On 22 December 2017, the Tax Cuts and Jobs Act was signed into law by President Trump. With it, the Act provides the most comprehensive overhaul of the US tax code in more than 30 years.
19 Feb. '18 1 min. Patrick T.F. Schrievers
The reformed US tax system will affect group companies doing business in the US. Furthermore, it will have an impact on other jurisdictions, which will look at the implications of the new measures for their own economy and tax system. Key provisions of the new US tax code are:
• Reduction of the Corporate Income Tax rate from 35% to 21% (excl. state/federal taxes).
• 100% Dividend Participation Exemption.
• Limitations on Net Operating Loss.
• Mandatory One-Time Transition Tax.
• Various provisions to prevent avoidance and base erosion, including additional CFC rules, interest expense limitations, provisions that disallow a deduction in relation to related party payments and anti-hybrid rules.
Please see our blog for a more detailed overview of the key measures and attention points for multinational groups with a branch or company in the US.