Glossary · Entity & Business
GILTI
GILTI is a US anti-deferral rule that can tax a US owner currently on the profits of a controlled foreign corporation, rather than only when distributed. It commonly affects Americans who own UK limited companies.
Global Intangible Low-Taxed Income
In more detail
GILTI was introduced to discourage shifting profit into low-taxed foreign companies. For a US citizen owning a UK limited company (a controlled foreign corporation), it can mean US tax on the company profits even if nothing is paid out. Elections such as Section 962 and high-tax exclusions can mitigate it. Note that under recent US legislation the GILTI regime is being renamed and revised (to NCTI) for tax years beginning after 31 December 2025 — the mechanism persists under the new label.
Related terms
Does GILTI apply to your situation?
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