The prospect of Donald Trump returning to the White House has sparked concerns of an impending global tax conflict, with experts warning of potential Republican retaliation against countries imposing additional levies on US multinationals.
A senior tax executive at a major multinational corporation shared with the Financial Times that 2025 could mark a critical turning point, describing it as the year “everything goes to hell in a handbasket” with businesses caught in the crossfire. Alan McLean, who chairs the Business at OECD tax committee, cautioned that using tariffs as a response to global tax measures would likely hamper economic growth by increasing operational costs and consumer prices.
The contentious issue centres on Republican opposition to a crucial element of the OECD global tax agreement. The deal, implemented this year, permits other nations to impose top-up taxes on US multinationals. Trump, who proudly identifies as a “tariff man,” has consistently wielded tariffs as a tool to protect US commercial interests.
The European Union appears to be a primary target for Republicans, who have labelled the undertaxed profits rule (UTPR) as discriminatory. This regulation enables countries to raise taxes on local subsidiaries of multinational groups that pay less than 15 per cent corporate tax in other jurisdictions.
Some experts speculate that the EU might compromise on UTPR enforcement to secure favourable export treatment, given its substantial €158bn trade surplus with the US. However, such changes would require unanimous agreement from all 27 EU member states, making any modification particularly challenging.
The implementation of the UTPR has already spread globally, with Australia, Canada, Japan, New Zealand, Norway, South Korea, Turkey, and the UK joining the EU in legislating the measure. Some jurisdictions have introduced a “temporary safe harbour” delaying the UTPR’s application until 2026 for countries with corporate tax rates above 20 per cent, demonstrating awareness of US concerns.
As Trump proposes reducing the US corporate tax rate to 15 per cent for domestic manufacturers, the potential for international tax disputes intensifies. The coming months may prove crucial in determining whether diplomatic solutions can prevent a full-scale global tax war.
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