支柱二全球最低税的规则竞争性认识

On the Understanding of the Competitiveness of Global Minimum Tax Rules under Pillar Two

从支柱二全球最低税的规则逻辑和计算逻辑总体观察,支柱二为全球各辖区设定一条15%的有效税率最低线,具有明显强势的规则竞争性,使得处于发展中国家地位的收入来源国制定税收优惠政策主权、税收利益、税收优惠技术处理和税收行政主权的空间受到挤压,税制竞争力受到削弱。为此,需要深刻认识支柱二全球最低税的规则竞争性,理解其不利影响和有利方面,做好有效应对,更好维护我国税收主权和税收利益。

Based on an observation of rule logic and calculation logic of the Global Minimum Tax under Pillar Two, a minimum effective tax rate of 15% for all jurisdictions around the world has been set up, which represents the obvious strong competitiveness of rules, makes the developing countries’ sovereign taxing rights squeezed in terms of formulating preferential tax policies, protecting tax interests, making technical treatments of preferential tax and tax administration. The competitiveness of the tax regimes of the developing countries(as source countries) becomes weakened. So, it is definitely necessary to deeply and thoroughly understand the rule competitiveness of the Global Minimum Tax under Pillar Two, including its favorable and adverse effects, so as to prepare for effective response and better safeguard China’s tax sovereignty and tax interests.