围绕全球最低税规则设计的分歧，是国家征税权的博弈。 2025年的岁末，按照BEPS（税基侵蚀与利润转移）包容性框架下的谈判议程，本应是全球税收改革收 获阶段性成果的时节，但是围绕OECD（经合组织）支柱二全球最低税的"并行方案"的激烈角力，却让 国际税收舞台上演了一场罕见的"年末大戏"。从爱沙尼亚在OECD静默程序中投下反对票，到波兰、捷 克等国相继表明立场，再到美国以报复性税收相威胁，这场围绕全球最低税规则设计的分歧，已不仅是 关键技术细节之争，更是国家征税权的博弈，是国际税收规则公平性和多边主义未来走向的一次集中检 验。 随着2025年临近尾声，现有UTPR过渡安全港将于2026年1月1日到期，美国企业将面临一项重要风险， 即一旦安全港到期，全球已实施支柱二全球最低税的60多个国家（地区）将有权通过UTPR规则对美国 企业的低税利润征税。也就是说，在美国不对美国企业低税利润征税的情况下，UTPR规则将使其他国 家（地区）获得征税权，正是要避免这种情况发生，美国政府急于在2025年年末推动"并行方案"通过， 甚至不惜重提《大而美法案》曾放弃的第899条报复性税收条款，将不接受方案的国家列为"税收不公正 国" ...

Group 1 - The article discusses the adjustments made by the Trump administration to previous tax policies, particularly through the Global Intangible Low-Taxed Income (GILTI) rules, which effectively implement a minimum tax practice expected to continue in subsequent terms [1][4]. - China is currently an observer in the OECD process and has a long-term wait-and-see attitude towards the two-pillar framework, with its current corporate income tax rate at 25%, and certain sectors benefiting from a reduced rate of 15%, aligning with global minimum tax standards [2][5]. - The OECD's two-pillar framework was developed to address tax challenges arising from digitalization, with Pillar One focusing on reallocating taxing rights for large multinational enterprises and Pillar Two establishing a global minimum corporate tax rate to curb tax base erosion and profit shifting [3][4]. Group 2 - The implementation of Pillar Two has seen some Southeast Asian and European countries, as well as Hong Kong, advance its adoption, with Hong Kong introducing a minimum tax mechanism to meet global standards despite a standard tax rate of 16.5% [5]. - There is a growing global consensus on stabilizing corporate tax rates around 15% through domestic laws, regardless of the specific future direction of Pillar Two [5]. - Chinese companies expanding overseas are advised to understand the tax regulations of their investment destinations and utilize professional platforms to navigate tax issues, particularly in light of the "safe harbor rules" in places like Hong Kong [5].

Core Viewpoint - The article discusses the increasing complexity and diversity of tax policies globally, particularly focusing on the BEPS 2.0 initiative aimed at ensuring fair tax distribution for multinational corporations based on their economic activities [1][2]. Group 1: BEPS 2.0 Overview - BEPS 2.0, under the G20 framework, aims to establish a global minimum tax rate of 15% for multinational corporations, ensuring that their effective tax rates do not fall below this threshold [1]. - Over 140 countries and regions have joined the implementation of the "Pillar Two" of BEPS 2.0, with recent announcements from Singapore, Japan, Hong Kong, Malaysia, and Thailand regarding its implementation [1][2]. Group 2: Impact on Chinese Enterprises - Chinese enterprises are increasingly investing abroad, with a total foreign investment amount reaching $147.9 billion in 2023, reflecting a compound annual growth rate of 8% over the past five years [3]. - The number of Chinese enterprises investing overseas has surged to approximately 600,000 in 2023, with a compound annual growth rate of 65% over the past five years [3]. Group 3: Tax Compliance and Challenges - Chinese companies must comply with local tax regulations in foreign markets, as failure to register could lead to penalties, especially under the requirements of "Pillar Two" [3]. - The complexity of "Pillar Two" presents challenges for Chinese enterprises, necessitating a thorough understanding of its implications on their international operations [3][4]. Group 4: Industry-Specific Insights - The implementation of "Pillar Two" is expected to have a limited impact on construction companies, as many small countries have not joined the initiative, and investments in these regions are minimal [4]. - Hong Kong is committed to implementing the GloBE rules under BEPS 2.0, which will require multinational groups with significant revenue to pay at least 15% tax in each jurisdiction they operate [4].

Group 1 - The implementation of the Hong Kong Stablecoin Regulation on August 1 is expected to attract stablecoin operators to establish their businesses in Hong Kong, as the regulatory framework is considered advanced [1] - The financial technology sector is optimistic about the development of stablecoins, which are believed to create significant opportunities in trade and investment markets, aiding in global currency diversification [1] - The number of mainland enterprises that have settled in Hong Kong over the past two and a half years is 630, accounting for approximately 48% of the total, indicating a strong trend of mainland companies using Hong Kong as a launchpad for international expansion [1] Group 2 - The introduction of the BEPS 2.0 framework, which includes a global minimum tax and a minimum top-up tax in Hong Kong, aims to address tax avoidance by multinational corporations, with Hong Kong's corporate tax rate at 16.5%, higher than the global minimum of 15% [2] - Despite geopolitical challenges, Hong Kong is viewed as having both risks and opportunities, with the Investment Promotion Agency focusing on enhancing connections with international markets while exploring emerging markets [2] - Since the implementation of a new company migration mechanism, two insurance companies have relocated to Hong Kong, highlighting the potential for business opportunities in the region [2]

Core Viewpoint - The "Big and Beautiful" Act, a significant pillar of Trump's economic policy during his second term, aims to fulfill his election promises regarding economic development and social welfare, with substantial implications for both the U.S. and other countries [1][2]. Group 1: Tax and Spending Implications - The "Big and Beautiful" Act is expected to reduce U.S. federal tax revenue by approximately $4.5 trillion over the next decade (2025-2034) due to the extension or permanent establishment of several provisions from the previous "Tax Cuts and Jobs Act" [2][3]. - The Act allows full tax deductions for research and development expenses and capital investments made in the U.S., reflecting a "trickle-down economics" approach aimed at economic recovery and job creation [2][3]. - The projected increase in U.S. national debt is estimated to be around $4.1 trillion to $5.5 trillion over the next decade, with the debt-to-GDP ratio expected to reach 127% by 2034 [3][9]. Group 2: International Tax Policy Changes - The Act continues and expands upon the previous tax reforms, tightening foreign tax credit rules and increasing the limit on foreign tax credits under the Global Intangible Low-Taxed Income (GILTI) provisions from 80% to 90% [4][6]. - The Act retains provisions for "retaliatory taxes" against countries imposing unfair taxes on U.S. companies, reflecting a strong stance on international tax sovereignty [5][6]. - The revisions to the Base Erosion and Anti-Abuse Tax (BEAT) rules indicate a more aggressive approach to taxing foreign entities, with significant implications for international tax relations [6][7]. Group 3: Domestic Spending and Policy Shifts - The Act significantly cuts spending on healthcare and social security by approximately $1.2 trillion while increasing defense spending, indicating a prioritization of military and border security initiatives [9][10]. - The termination of clean energy tax credits marks a shift away from the previous administration's green policies, emphasizing traditional fossil fuel production and usage [8][9]. - The Act's overall approach to tax policy is seen as a manifestation of "tax power," necessitating vigilance from other nations regarding potential impacts on their own tax systems [8][9].

Core Viewpoint - The article discusses the recent agreement between the U.S. Treasury and the G7, which exempts U.S. companies from certain foreign taxes in exchange for the withdrawal of the proposed Section 899, also known as the "retaliatory tax" [1][3]. Group 1: Agreement Details - The U.S. Treasury estimates that the agreement will prevent U.S. companies from paying over $100 billion in taxes to foreign governments over the next decade [3]. - The G7 will work to implement the agreement in the coming weeks to months, ensuring that the OECD's second pillar tax does not apply to U.S. companies [3][4]. - The OECD's international tax reform framework includes two pillars, with the second pillar aiming to impose a global minimum tax rate of around 15% to curb tax avoidance [3][4]. Group 2: Political Context - The Section 899 proposal was drafted by Republican members of the House and supported by the White House, aimed at countering discriminatory taxes imposed by several countries on U.S. companies [3][4]. - The agreement reflects a significant difference in economic models between Anglo-American countries and continental European nations, with the former favoring lower tax rates [4]. Group 3: Market Reactions - The "retaliatory tax" raised concerns on Wall Street, as it could complicate foreign investment in the U.S. and negatively impact U.S. assets [6][7]. - International investors have increasingly concentrated their investments in U.S. assets, driven by a tech boom and a strong dollar, which has raised concerns about potential market corrections [8].

Group 1: Guangdong Private Enterprises Trade - In the first four months of this year, the import and export value of private enterprises in Guangdong reached 1.89 trillion yuan, a year-on-year increase of 5.6%, accounting for 63.9% of the province's total import and export value during the same period [1] Group 2: Hong Kong Tax Legislation - The Hong Kong Legislative Council passed the "2024 Taxation (Amendment) (Minimum Tax for Multinational Enterprises) Bill," which will implement a minimum tax rate of 15% for multinational enterprises with an effective tax rate below this threshold, expected to generate approximately 15 billion HKD in additional revenue annually starting from the 2027-2028 fiscal year [2][3] Group 3: Shenzhen Education Sector - The booking volume for "Gaokao rooms" in Shenzhen has increased by over 180% compared to the same period in 2023, placing it among the top ten cities nationwide for such bookings, reflecting heightened societal attention on the college entrance examination [4] Group 4: Foshan's City Ranking - Foshan has re-entered the "New First-tier Cities" list after two years, indicating significant improvements in urban strength, industrial development, and economic vitality, as well as its competitive position in the regional development landscape [5] Group 5: Shenzhen Stock Market Performance - The Shenzhen Component Index closed at 10,003.27 points, down 0.26% [6] Group 6: Stock Performance Highlights - Notable gainers in the Shenzhen market included Shuiyang Co., Ltd. with a 20.01% increase, and Huanlejia also up by 20.01%, while Anke Detection saw a decline of 12.97% [7]