BEAT (Base Erosion and Anti-Abuse Tax)
The Base Erosion and Anti-Abuse Tax is a US minimum tax, introduced by the 2017 TCJA, that applies to large corporations (broadly those with US$500m or more in average annual gross receipts) which make substantial deductible payments, such as interest or royalties, to foreign affiliates. BEAT adds those payments back into the tax base and imposes a minimum effective rate, neutralising the erosive effect of related-party payments. The 2025 One Big Beautiful Bill Act set the BEAT rate permanently at 10.5%, cancelling a previously scheduled rise to 12.5%. It applies only to the largest companies.
ByLoopholeKiln EditorialPublished
Figures current as of·Corrections
← Tax-avoidance glossary: 31 terms in plain English
Example: a group whose US subsidiary pays large royalties to a zero-tax parent has those royalties added back under BEAT, so a minimum 10.5% effective rate still applies.
Why it matters to a small business: BEAT applies only to some of the world's largest corporations. It has no relevance to small businesses, and the US$500m receipts threshold means you will never be in scope.