Interaction of Domestic Law Liquidation Losses and GloBE Rules from a Chilean and Dutch Perspective

Journal
Mahu Martínez, P.A.; Franco Allen, A.
Chile; Netherlands; OECD
Bulletin for International Taxation 2025 (Volume 79), No. 3
Price USD 45

Tax losses arising from company liquidation may be deductible under Dutch and Chilean law but excluded from the effective tax rate under the GloBE Rules, leading to potential top-up taxes. Legislators should limit the exclusion period for these losses to avoid taxing non-existent income upon GloBE enactment.