id	author	title	date	pages	extension	mime	words	sentence	flesch	summary	cache	txt
taxlaw-12714	Parada, Leopoldo	Global Minimum Taxation: A Strategic Approach for Developing Countries	2024	25	.pdf	application/pdf	14202	496	42	The first of these rules is known as the Income Inclusion Rule (IIR), and it is triggered with priority in the country of the ultimate parent entity (UPE) of an MNE group or that of the intermediary parent entity under certain circumstances in cases in which a minimum effective level of corporate income tax of 15% is not achieved in the country where the foreign subsidiaries of the MNE group are located.10 In other words, developing countries shall act strategically, keeping tax incentives without the elements of corporate income tax, or they shall try to make these incentives as efficient as possible for purposes of the calculation of the ETR.87 Let me take the example of refunding negative corporate tax in the form of a refundable credit to illustrate the foregoing.	cache/taxlaw-12714.pdf	txt/taxlaw-12714.txt