US FTC for UK DPT?
EY’s Global Tax Alert provides a summary of the US congressional developments, including a review for US Foreign Tax Credit (FTC) applicability of the UK’s Diverted Profits Tax (DPT) which went into effect April 2015.
This review highlights a renewed focus on receiving a US FTC for income that may have been taxed in another (low-tax) jurisdiction and for which a country asserts a right to tax in its jurisdiction. The answer is not yet clear, and this analysis also points the way forward for similar tax measures being legislated by various countries.
Strategizing Multinational Tax Risks 