This article, “Qualified Domestic Minimum Top-Up Tax Allocation: Survey and Examples,” was originally published in the September 1, 2025 issue of Tax Notes International (cover and pp. 1313-1323). It is reproduced on this blog with the publisher’s permission.
In this article, the authors summarize the qualified domestic minimum top-up tax rulesin Canada, France, Germany, Italy, Spain, and the United Kingdom, providing examples of typical mergers and acquisitions transactions to illustrate their application.