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Tax Newsflash

This newsletter series keeps you abreast of the latest tax and business developments.

Latest Tax Newsflash

OECD Pillar Two: Qualified jurisdictions and further guidance

27 January 2025

On 15 January 2025, the OECD/G20 Inclusive Framework on BEPS (”inclusive framework”) published a compilation of Pillar Two-related documents including a central record of jurisdictions’ domestic Pillar Two legislation with transitional qualified status. Further administrative guidance has also been released in respect of deferred tax assets arising from tax benefits provided by governments.

The Pillar Two global minimum tax rules (“model rules”) have been agreed by more than 140 members of the inclusive framework. Jurisdictions are in the process of implementing rules in local legislation, which began to apply as from January 2024. The Pillar Two rules apply to large multinational groups with annual consolidated group revenue of at least EUR 750 million, and result in “top-up” tax amounts to bring the overall tax on profits in each jurisdiction where a group operates up to a 15% minimum effective tax rate. The key components are: qualified domestic minimum top-up taxes (QDMTTs) which allow jurisdictions to charge any top-up taxes due in respect of local profits; the income inclusion rule (IIR) under which parent company jurisdictions apply the top-up tax rules on a top-down basis; and the undertaxed profits rule (UTPR) which will apply as a secondary (backstop) rule where the other rules have not been fully applied.

Where a permanent QDMTT safe harbor applies, a business will be able to elect to prepare a single QDMTT computation for a jurisdiction, and no additional top-up tax will arise in other jurisdictions under the IIR or UTPR. For the QDMTT safe harbor to apply, the domestic minimum tax must not only be “qualified,” but the domestic legislation must also meet an additional set of QDMTT safe harbor standards. (It is therefore theoretically possible that a jurisdiction could introduce rules that are a “qualified” QDMTT but do not qualify for the QDMTT safe harbor).

Year 2018

2019 Tariff Adjustments
29 December 2018

Guidance issued on transition rules for preferential IIT policies 
28 December 2018

Agreements on Trade in Goods under CEPA are signed by Chinese Mainland, Hong Kong and Macau
18 December 2018

China will suspend, for a period of three months, the additional tariff imposed on cars and car parts originated from the United States
17 December 2018

Overview of customs opportunities and challenges arising from innovations in China (Guangdong) Pilot Free Trade Zone
13 December 2018

Grasp new opportunities, meet new challenges——Customs issues new regulations on credit management
30 November 2018

Temporary tax exemption granted for bond interest derived by foreign institutional investors
28 November 2018

New guidance relaxes requirements for foreign investors to benefit from deferral of dividend withholding tax
23 November 2018

China has established bilateral CbC report automatic exchange relationships with 42 jurisdictions
12 November 2018

Export VAT refund policies further enhanced
29 October 2018

Updates on the Proposed Abolishment of the Macao Offshore Law
23 October 2018

China announces more tariff cuts on imported goods
8 October 2018

Proposed abolishment of the Offshore Law by the Macao SAR Government
27 September 2018

China's latest tariffs on USD60 billion worth of U.S. imports will come into force on 24 September
19 September 2018

China to increase VAT export refund rates from 15 September 2018
14 September 2018

OECD releases guidance on transactional profit split method
23 August 2018

OECD releases guidance on hard-to-value intangibles
21 August 2018

SAT clarifies seven VAT issues
15 August 2018

U.S. adds 44 China-based entities to the Department of Commerce Entity List 
13 August 2018   

China Tariff List 2 will come into force on 23 August 
10 August 2018                                                                                                

China's decision to impose tariffs on U.S. origin goods worth US$60 billion  
7 August 2018

New immigration scheme for technology talent admission in the Hong Kong Special Administrative Region brings new opportunities and synergies
2 August 2018

OECD discussion draft on financial transactions
9 July 2018

China Tariff List 1 coming into force
9 July 2018

2018 Guidance issued on refund of uncredited input VAT to certain industries
2 July 2018

R&D super deductions reinstated for cross-border contract R&D arrangements
2 July 2018

China tariff measures in response to the decision of the United States to impose tariffs on $50 billion of Chinese goods
19 June 2018

China to further cut tariffs on daily consumable products
4 June 2018

Challenges and opportunities in investing and doing businesses in Greater Bay Area from tax and business perspectives
1 June 2018

Pilot program launched for tax-deferred commercial pension insurance
24 May 2018

China cuts car and car parts import tariff
23 May 2018

China releases a favorable VAT policy for sales of cancer drugs
28 April 2018

SAT clarifies implementation issues for VAT rate cuts and conversion to small-scale VAT payer status
25 April 2018

China to remove customs duty on cancer drugs
24 April 2018

China imposes temporary antidumping measures on imports of sorghum from U.S.
18 April 2018

China announces VAT rates cuts
29 March 2018

China to consider increasing tariffs on U.S. goods
26 March 2018

VAT rate structure likely to be reduced from three to two
6 March 2018

GAC publishes implementation guidance on new customs advance ruling regime
2 February 2018

SAT releases 2017 Enterprise Income Tax Return Forms
29 January 2018

Advance ruling regime introduced for customs purposes
12 January 2018

New rules issued on deferral of withholding tax on dividends paid to foreign investors and reinvested in China
9 January 2018

Year 2015

Mainland Chinese tax treatment of investors in Mainland-Hong Kong mutually recognized publicly offered funds clarified
25 December 2015

Expansion of products eligible for processing trade relief: Are you impacted?
18 December 2015

SAT clarifies EIT incentives to stimulate technological innovation
11 December 2015

SAT clarifies new IIT incentives for qualifying employees and shareholders of HNTEs
10 December 2015

SAT clarifies new rules on tax treaty benefit claims
25 November 2015

SAT simplifies administrative procedure for resident enterprises to apply preferential EIT treatment
24 November 2015

Impact of Trans-Pacific Partnership free trade agreement on Chinese companies
18 November 2015

SAT issues "Catalogue of Codes for Tax Exemptions and Reductions"
18 November 2015

China enhanced super deduction for R&D expenses
13 November 2015

Common Reporting Standard (CRS) in Hong Kong
5 November 2015

Income tax incentives extended nationwide to stimulate technological innovation
3 November 2015

VAT zero-rated services: Scope expanded
3 November 2015

U.S. extends FATCA transition rules and modifies other rules
23 September 2015

New guidance issued to stimulate technological innovation
29 June 2015

SAT issues new rules on deduction of salaries and welfare expenses
29 May 2015

State Council suspends "clean-up" of preferential policies
21 May 2015

SAT issues new guidance following elimination of tax-related administrative approvals
19 May 2015

SAT issues tax audit plans for 2015
15 May 2015

Land appreciation tax and deed tax relief extended to promote mergers and acquisitions
29 April 2015

Guidance issued to facilitate corporate reorganizations
14 January 2015

State Council calls for changes to local preferential policies
8 January 2015

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