G7税收新规允许“美国例外”：全球最低企业税遇挫，数字税何去何从？

Core Viewpoint - The G7 agreement allows large U.S. multinational companies to avoid paying additional overseas taxes, fundamentally altering the global minimum corporate tax reform established in 2021 [1][4]. Group 1: G7 Agreement Details - The G7 reached an agreement to implement a "parallel" tax solution, exempting U.S. multinationals from the Income Inclusion Rule (IIR) and the Under-Taxed Payment Rule (UTPR) [1]. - In exchange, the U.S. will remove the controversial Section 899 from the "Big and Beautiful Act," which authorized retaliatory taxes against countries with discriminatory tax policies [1][6]. - The G7 statement emphasizes that this agreement aims to maintain the achievements made under the OECD/G20 Inclusive Framework in addressing Base Erosion and Profit Shifting (BEPS) [1]. Group 2: Implications of the Agreement - The removal of Section 899 is crucial for achieving consensus and providing a stable environment for discussions within the Inclusive Framework [6]. - The agreement is expected to save U.S. companies approximately $100 billion in foreign tax burdens over the next decade [6]. - The G7's approach has been criticized for prioritizing the interests of multinationals over small and medium-sized enterprises and ordinary citizens [1][8]. Group 3: International Tax System Stability - The implementation of the parallel system is anticipated to further stabilize the international tax system and promote constructive dialogue regarding the taxation of the digital economy [9]. - The digital services tax (DST) has been a point of contention, particularly between the U.S. and European countries, with various tax rates implemented across Europe [9]. - The U.S. has previously taken a strong stance against digital taxes, viewing them as targeting American companies [10][11].