This article defends
UTPR (formerly known as the Under Taxed Payments Rule or Under Taxed Profits
Rule) which is a critical backstop under Pillar Two’s Global Anti Base Erosion
Rules (GloBE Rules) ensuring a 15% global minimum tax. It examines the UTPR’s
design evolution and advocates for its implementation as an adjustable-rate tax
mechanism tied to domestic entities’ income. By framing anti-avoidance as
grounds for expanded tax nexus, the article contends that the UTPR’s legitimacy
must be a corollary of the Income Inclusion Rule’s (IIR’s) acceptance (as
controlled foreign corporation (CFC)-like), upholding equity in global tax
order.