Challenges and Response Strategies for MNEs under the Global Minimum Tax Rules. Este artículo no está disponible.Challenges and Response Strategies for MNEs under the Global Minimum Tax Rules

This article analyzes the strategic framework of the Pillar Two global minimum tax, provides a structured review of its implementation status, and examines the challenges faced by multinational enterprises under the minimum tax regime across typical scenariosThis article analyzes the strategic framework of the Pillar Two global minimum tax, provides a structured review of its implementation status, and examines the challenges faced by multinational enterprises under the minimum tax regime across typical scenarios. While sorting out the evolution of Pillar Two rules and the implementation differences across jurisdictions, the paper combines typical scenarios of multinational companies to analyze their global business layout, especially the inherent conflicts between traditional structures such as Hong Kong-Singapore dual holding, VIE and Red Chip structures, and the implementation of the Pillar Two minimum tax. It identifies core challenges from four dimensions: compliance pressure, tax burden costs, structural restructuring, and subsidy conflicts, and constructs a four-dimensional response system of “Rule Exemption – Policy Adaptation – Structure Restructuring – Compliance Management”.