美国强推“并行方案”：全球最低税下的国家征税权博弈

Core Viewpoint - The ongoing disputes surrounding the design of the global minimum tax rules reflect a struggle for national taxation rights and serve as a critical test of the fairness of international tax regulations and the future of multilateralism [1] Group 1: Global Minimum Tax Framework - The global minimum tax is a key component of the OECD/G20 international tax reform, aimed at curbing tax rate competition among multinational corporations by ensuring they pay at least a 15% effective tax rate globally [2] - The global minimum tax is implemented through the GloBE rules, which include the Income Inclusion Rule (IIR) and the Undertaxed Payments Rule (UTPR) [2] Group 2: Taxation Rights and Rules - Under the global minimum tax framework, jurisdictions with effective tax rates below 15% can impose a Qualified Domestic Minimum Top-up Tax (QDMTT) to raise their rates, preventing other jurisdictions from taxing the income sourced from that jurisdiction [3] - If a low-tax jurisdiction does not impose a QDMTT, the IIR and UTPR rules will transfer taxation rights to other jurisdictions, ensuring that the effective tax rate remains above 15% [3] Group 3: U.S. Position and Parallel Plan - The U.S. has expressed dissatisfaction with the global minimum tax, particularly under the "America First" agenda, leading to the proposal of a "parallel plan" that allows U.S. tax rules to operate alongside the GloBE rules [4] - This parallel plan grants U.S. multinational corporations exemptions from the IIR and UTPR, undermining the uniform application of the global minimum tax across jurisdictions [4] Group 4: Implications for U.S. Corporations - As the transition period for the UTPR is set to expire on January 1, 2026, U.S. corporations face significant risks of being taxed by over 60 countries that have implemented the global minimum tax if the parallel plan is not adopted [5] - The urgency for the U.S. government to push through the parallel plan is heightened by the impending expiration of the UTPR transition safety harbor [5] Group 5: Small Countries' Resistance - Estonia's opposition to the global minimum tax is notable, as it seeks similar exemptions as the U.S. to maintain its unique tax system that attracts global unicorns [6] - Other low-tax jurisdictions within the EU, such as Latvia and Lithuania, share similar concerns and wish to delay the implementation of the IIR and UTPR rules beyond 2030 [7] Group 6: Challenges of Multilateralism - The debate over the parallel plan highlights structural contradictions in global tax governance, where the need for supernational solutions clashes with national sovereignty concerns [8] - The push for a parallel plan by the U.S. risks creating a dual standard in global tax rules, potentially fragmenting the global minimum tax framework and undermining efforts to curb tax rate competition [8] Group 7: Future of Global Tax Governance - The ongoing negotiations reflect the difficulty of balancing national tax sovereignty with the need for collective action in a globally interdependent economy [9] - A return to genuine multilateralism, with inclusive designs and differentiated arrangements, is essential for establishing a new order that respects tax sovereignty while enabling global cooperation [9]