Qualified Domestic Minimum Top-up Tax Plays Leapfrog in Pillar Two:On the Readjusted Distribution Order of the Global Minimum Taxation(Part 2)
In December 2021,the OECD released Tax Challenges Arising from the Digitalisation of the Economy—Global Anti-Base Erosion Model Rules(Pillar Two),which introduced the Qualified Domestic Minimum Top-up Tax(QDMTT)for the first time,making the source state of the MNE group's excess profits take the lead in the distribution order of the global minimum tax,leapfrogging the residence state of the large MNE group's parent entity.The paper analyzes the function and key issues of the implementation of the QDMTT,and argues that the QDMTT is a result of the interest game within the G7.Combined with the background of ongoing game of current global minimum tax,the paper discusses the impact of the QDMTT on China and China's countermeasures.
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