Overview

• Section 899 in the “One Big Beautiful Bill” proposes a 5 percent annual surcharge on dividends and interest for investors from countries with taxes deemed discriminatory.
• Surcharges would accumulate to an extra 20 percent over four years for those affected by Digital Services Taxes or the EU’s Undertaxed Profit Rule.
• Treasury projections attribute approximately $116 billion in additional revenue over the next decade to the new surcharges.
• European companies and investors warn of significant cost increases on US holdings if the measure becomes law.
• The Senate’s decision will determine whether the United States escalates its trade conflict with Europe and prompts EU retaliation measures.