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Base Erosion Payment
                                                                                                  (BEP) /

                             Base
                                            Erosion Tax Benefit (BETB)





                                      BEP                                                     BETB



                        amount paid or accrued
                                                                                                             allowed
                Any                                                      The deduction that                 i s
                     the taxpayer to a FRP with
                by                                                       in the taxable year
                                                                                                           for the BEP
                              to which a deduction is
                respect
                                             Chapter 1
                allowable under


                Any                                                      The deduction allowed in the
                        amount paid or accrued
                     the taxpayer to a FRP in
                                                                                                for depreciation
                by                                                       taxable year
                                                                              amortization with respect to
                connection with the acquisition  or
                    depreciable or amortizable
                of                                                       the acquired property
                property





                  •  See discussions
                                                 below for additional rules, including exceptions







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