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Managing the BEAT: What Role Can Treasury Play?

How corporate treasury teams can evaluate the pricing and structure of intercompany funds flows to help manage potential tax liabilities.

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Stock illustration: Drummer keeping the beat

The base erosion and anti-abuse tax known by the acronym “BEAT” was enacted by the Tax Cuts and Jobs Act (TCJA) as a means of limiting intercompany funds flowing out of the United States. For companies that meet certain criteria, the BEAT acts as an alternative minimum tax, with the potential for the additional tax payable to be significant. As such, the BEAT continues to be a significant area of focus for multinationals with U.S. operations, particularly large multinationals with material U.S.-outbound intercompany flows.

Effective management of BEAT exposures is highly specific to the facts and circumstances of each multinational and requires those impacted to perform critical reviews of operations and supporting structures that result in material funds flows. Many intercompany flows that touch the corporate treasury group appear relevant; these could include interest on loans, lease-financing payments, guarantee fees, and service payments to non-U.S. treasury centers.

Therefore, treasury professionals must coordinate with their colleagues in tax and other areas of the company to manage the impact of intercompany financial flows on any new, and potentially substantial, tax liabilities under the BEAT provision.

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