【税务洞察】OECD发布“并行安排”一揽子方案：支柱二政策迎来重大调整

Core Viewpoint - The OECD has released an 88-page "Parallel Arrangement" plan under the BEPS global minimum tax reform framework, aimed at optimizing rule implementation and reducing compliance burdens while addressing international concerns about the applicability and practicality of the rules [1]. Summary by Sections Key Mechanisms - The "Parallel Arrangement" includes several key mechanisms, primarily focusing on the SbS Safe Harbour, which aims to prevent multinational groups with ultimate parent companies in qualifying jurisdictions from being subject to IIR or UTPR [2][5]. - A jurisdiction must meet four conditions to be recognized as having a "qualifying SbS system," including a domestic tax system with a nominal tax rate of at least 20% and a CAMT rate of 15% or higher, or having implemented QDMTT [3][6]. Evaluation and Compliance - The Inclusive Framework will assess existing tax policies that have been enacted and effective by December 31, 2025, against the qualifying standards set by the SbS Safe Harbour in the first half of 2026 [4]. - Currently, only the United States has publicly indicated that its tax system may qualify for the SbS Safe Harbour mechanism, with limited benefits expected for other jurisdictions [5]. New Safe Harbours - The UPE Safe Harbour will replace the existing UTPR Safe Harbour for fiscal years starting on or after January 1, 2026, allowing jurisdictions that meet the qualifying domestic tax system conditions to have a zero UTPR tax liability [7][8]. - The SESH is introduced as a simplified mechanism for compliance, applicable from fiscal years starting on or after December 31, 2026, allowing jurisdictions to opt for early adoption under certain conditions [9][10]. Substance-based Tax Incentive Safe Harbour - The SBTI Safe Harbour allows certain qualifying tax incentives to be included in the "Qualified Tax Incentive" category, which can enhance the overall effective tax rate of a jurisdiction, potentially exempting it from supplementary tax obligations [11][12]. - A cap on adjustments based on substance is set, limiting the adjustable amount to 5.5% of qualified wage costs or depreciation expenses, or 1% of the book value of qualified tangible assets [12]. Overall Implications - The release of the "Parallel Arrangement" signifies a transition from the initial implementation phase of Pillar Two rules to a more refined and regular adjustment phase, reflecting the OECD's response to the business community's demands for compliance feasibility and certainty [14]. - Companies are advised to conduct a comprehensive review of existing tax incentive policies, track legislative developments, and update tax burden forecasts for 2026 and beyond, considering the implications of the new mechanisms [19].