[20220310]IF11874_解决利润转移的国际税务提案：支柱1和2.pdf

https:/crsreports.congress.gov Updated March 10, 2022International Tax Proposals Addressing Profit Shifting: Pillars 1 and 2On June 5, 2021, finance ministers of the G7 countries, including the United States, agreed in a communiqu to two proposals addressing global profit shifting. They agreed to Pillar 1, allocating rights of taxation of residual profits to market countries of at least 20% for certain digital services for large profitable multinationals while eliminating digital services taxes. They also agreed to Pillar 2, imposing a global minimum tax of at least 15%. These proposals were developed in OECD/G20 blueprints for addressing profit shifting and base erosion, which involved participation by 139 countries. The G7 agreement is a general agreement and does not address the detail in these blueprints. This G7 communiqu is a first step in the process of reaching a multilateral agreement and is not binding. On July 10, the G20 endorsed the plan. Some aspects might require legislative changes. The OECD reported on October 8 that 136 out of 140 countries participating have joined the framework. The agreement does not mention a specific revenue threshold, but the OECD in anothe