Export neutrality the country of origin of the controlled

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entity is recognized as having the right to impose the first slice of taxation on income (also referred to as "first bite at the apple  which is subsequently deducted from the final taxation due to the base country of the controlling entity. Without a doubt, a customary mechanic in international taxation standards. On December however, new regulations introduced by the US Treasury (TD9959) created a new requirement for the recognition of tax credits on taxes abroad. Applicable from fiscal years beginning after the publication of the new rule, the consolidated requirements.

Crediting now reflect the following list, if seen in a simplified way: Requirement #1: Realization Requirement Receipts Requirement #3: Net Income Requirement #4: Attribution ( new requirement ) In general terms, the fourth and new requirement imposes the need for a connection (or attribution) between the origin/source EX Mobile Phone Numbers of the net income subject to tax and the foreign jurisdiction whose tax jurisdiction is exercised over the taxable event. The purpose of the attribution rule was originally to deny credit for foreign taxes that did not comply with American taxation standards.



It is understood that the regulation launched by the American treasury has a certain connection with the attempt to limit the unilateral efforts of countries that have decided to tax non-resident companies with highly mobile income, in what has been called "digital taxes". This intention can be interpreted in speeches by the American Treasury Secretary, Janet Yellen, notably in her speech before the American Congress and, more specifically, in response to questions made by Senator Rob Portman (R-OH) related to the new rule.