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

Journal
Chile; Netherlands; OECD
Bulletin for International Taxation 2025 (Volume 79), No. 3
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.