Squire Patton Boggs’ Jeff VanderWolk, addresses Tarcísio Diniz Magalhães’s recent article that challenges himself and others on UTPR’s nexus problem.
The issue is whether the UTPR (now known as the undertaxed profits rule) violates accepted principles of international taxation by enabling UTPR jurisdictions to assess tax on a resident entity regarding low-taxed profits earned by a nonresident affiliate that is not owned by the resident entity and has never had any dealings with the resident entity or any other resident of the UTPR jurisdiction.
*This article was first published in Tax Notes on December 12, 2022.
