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140多个国家和地区加入支柱二 企业“走出去”需制定属地化准则
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].