The US government has issued draft regulations setting out how the new base erosion and anti-abuse tax (BEAT), a provision of the Tax Cuts and Jobs Act 2017, will apply to large companies that claim tax relief on payments to foreign entities.
The new s59A provision, part of the US' move from a worldwide to a territorial business tax system, sets an additional minimum tax on corporate profits on top of the company's normal tax liability, beginning from the 2018 tax year.
