——访中国民航大学经济与管理学院教授、中国国际税收研究会学术委员励贺林 图片来源/新华社 ■ 中国经济时报记者 郭锦辉 数字经济发展带来新经济、新业态、新模式，在改变人们的生产生活方式、重塑经济社会发展格局的同时，也对现行税收体系带来了冲击。如何看待数字 经济全球税收治理带来的重要影响？中国经济时报记者专访了中国民航大学经济与管理学院教授、中国国际税收研究会学术委员励贺林。 数字经济全球税收治理博弈激烈 中国经济时报：目前，数字经济全球税收治理呈现怎么样的格局？数字经济税收对国际税收规则产生了哪些影响？ 励贺林：当前，国际形势变乱交织，联合国和多边主义受到冲击，全球治理赤字持续扩大，数字经济全球税收治理同样遇到重大挑战，国际税收合作的道 路并不平坦。在2021年10月13日于美国召开的二十国集团（G20）财长和央行行长会议上，各国财长和央行行长就应对经济数字化税收挑战的"双支柱"方 案达成最终共识，这是世界各国携手共同解决全球性问题的一次成功实践，对于建立公平合理的国际经济秩序具有十分重要的现实意义和深远的历史意 义。然而，国际税收新规则的道路并不平坦，尤其是特朗普开启第二个美国总统任期以来，数字经济全球税收 ...

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 - Trump's recent threats regarding digital taxes could destabilize the "Two-Pillar" framework, leading to increased uncertainty and potential backlash from affected countries [1][2]. Group 1: Digital Tax and U.S. Companies - Digital taxes are primarily aimed at U.S. tech giants like Apple, Amazon, Facebook (Meta), and Google, with bipartisan opposition in the U.S. against such taxes being viewed as discriminatory [2][3]. - Trump's strong stance against digital taxes includes potential tariffs and export restrictions, particularly targeting the EU's upcoming Digital Markets Act [2][3]. Group 2: International Taxation and the "Two-Pillar" Framework - The digital tax issue reflects a broader competition over taxation rights among nations, as traditional tax rules fail to address the profits of digital companies operating across borders [4][5]. - The G20 has tasked the OECD with designing the "Two-Pillar" framework to address these challenges, aiming to reshape international tax rules to prevent unilateral tax measures like digital service taxes [4][5]. Group 3: U.S. Government's Position - The Biden administration supports the "Two-Pillar" framework, emphasizing the importance of a global minimum tax rate of 15% to prevent tax competition [6][7]. - The U.S. has made commitments to the "Two-Pillar" framework, including a requirement for countries to abolish digital service taxes in exchange for benefits under Pillar One [7][8]. Group 4: Political Challenges and Reactions - The Biden administration faces domestic opposition, particularly from Republican lawmakers who argue that the U.S. has compromised too much on Pillar One and that the global minimum tax infringes on U.S. tax rights [8][9]. - Trump's withdrawal from international tax negotiations has led to a resurgence of interest in unilateral digital service taxes among other countries, as they may feel compelled to act independently if consensus is not reached [9][10]. Group 5: European Response - The EU has firmly rejected Trump's threats regarding digital service taxes, asserting its sovereign right to regulate U.S. companies within its jurisdiction [10][11]. - The EU's commitment to digital service taxes remains strong, with plans to enhance regulatory measures despite U.S. pressure [10][11].