重塑全球税收秩序：“支柱二”五大安全港破局实操困境

Core Viewpoint - The OECD's BEPS 2.0 project introduces a new international tax governance framework centered around a global minimum tax to address cross-border tax imbalances caused by "race to the bottom" tax competition among countries [1] Group 1: Parallel Arrangement - The OECD/G20 Inclusive Framework has released a "Side-by-Side Package" aimed at optimizing the implementation of the global minimum tax, addressing practical challenges [1] - The "parallel mechanism safe harbor" (SbS safe harbor) is designed for multinational groups in jurisdictions with high-standard tax systems, allowing exemptions from IIR and UTPR if certain conditions are met [2] - Currently, only the United States qualifies for the SbS safe harbor due to its implementation of the Corporate Alternative Minimum Tax (CAMT), significantly reducing the tax obligations for its multinational enterprises [2] Group 2: Innovations in Safe Harbor Mechanisms - The "Side-by-Side Package" includes innovations in four additional safe harbor mechanisms: Ultimate Parent Entity (UPE) safe harbor, transitional CbCR safe harbor extension, Simplified Effective Tax Rate Safe Harbor (SESH), and Substance-Based Tax Incentive Safe Harbor (SBTI) [2] - These five safe harbors are designed to address various tax-related issues and provide practical solutions, enhancing the maturity and implementation of the global tax governance framework [2] Group 3: Impact of Pillar Two Rules - According to OECD estimates, the full implementation of the Pillar Two rules is expected to reduce global profit shifting by over 50% and generate an additional $37 billion in global corporate income tax revenue annually [3] - As of January 12, 2026, over 70 jurisdictions have implemented the Pillar Two rules, including all EU member states and major economies like the UK, Singapore, and Canada [3] - Hong Kong's initiation of the global minimum tax and local minimum supplement tax in 2025 marks a significant step in cross-border tax governance in the Asia-Pacific region [3] Group 4: Future Tax Coordination - Although China and the United States have not publicly announced domestic legislative plans, the OECD's "Side-by-Side Package" provides a framework for potential tax coordination [3] - The release of the "Side-by-Side Package" signifies a transition from the initial implementation phase of the Pillar Two rules to a more refined and regular adjustment phase, reflecting OECD's commitment to tax fairness while addressing business compliance needs [3]