英文

G7's global minimum corporate tax rates regime

【明報專訊】The Group of Seven (G7) countries have reached a historic agreement in principle to introduce a global minimum corporate tax rate, which will be at least 15%. The Hong Kong government says that it will respond to changes in the global taxation system and maintain Hong Kong's competitiveness. In the era of the new economy, multinational giants take advantage of the differences in tax rates between regions to avoid taxation rampantly and pay ridiculously low taxes. Global efforts should be made to curb the practice.

After the Cold War ended late last century, economic globalisation began. In order to attract multinational companies to set up headquarters in their countries, different national governments have been rushing to lower corporate tax rates for decades. The rapid development of the Internet has also led to the emergence of the new economy. Multinational giants in Europe and the US leave their countries in droves to avoid taxation. The governments of developed powers become the greatest losers, as they have lost huge amounts of tax revenues. As for the big winners, they certainly include the many multinational giants and a number of countries and regions that attract corporations with ultra-low tax rates, an example being Ireland. In the US, a survey found that Microsoft, Amazon, Facebook, Alphabet (Google's parent company), Netflix and Apple have paid only US$219 billion in taxes over the past 10 years, accounting for only 3.6% of their total profits, which amounted to US$6 trillion. Take Microsoft as an example. Its Irish subsidiary does not conduct much concrete business. Last year, its profit was reportedly as high as US$315 billion. Since the company is registered in Bermuda, it is not required to pay local taxes according to Irish law. And since Bermuda does not levy a corporate tax, Microsoft's Irish subsidiary is virtually outside the tax net.

Multinational giants in Europe and the US exploit the differences in taxation systems to transfer profits from regions of high tax rates to their financial accounts in regions of low tax rates to avoid tax. A damning indictment of the injustices of the global capitalist system in the 21st century, this practice should be reined in by the international community. The US corporate tax rate is currently 21%. The Biden administration wants to raise it to 28%. Facing enormous resistance domestically, it is uncertain whether the hike can be achieved.

The global minimum corporate tax rates regime is likely to be in place, and the possibility of a deal by the end of this year cannot be ruled out. Hong Kong must be prepared for it as soon as possible. Under Hong Kong's current corporate profits tax regime, the first HK$2 million of a company's profit is taxed at a rate of 8.25%. For profits on top of the HK$2 million, the standard tax rate is 16.5%. The former tax rate is mainly for small and medium-sized enterprises and might not be affected by the global minimum corporate tax rates regime. As for the 16.5% tax rate, it is higher than the global minimum corporate tax rate proposed by the G7 countries, so there is no problem either for the time being. However, it must be pointed out that the minimum corporate tax rate is a complicated subject. To promote the development of specific industries, many countries and regions provide tax concessions for enterprises, and the actual tax rate will be affected.

The global minimum corporate tax rate is a brand new thing, and it remains to be seen how it will be pursued in practice. Hong Kong's simple and low tax system is a major selling point for attracting investment, and it will be a good thing if Hong Kong can maintain it. However, the time when a government can attract investment with low tax rates might be gone forever. The government cannot rely on the city's existing advantages forever. It is necessary for Hong Kong to boost high-tech development and create a better business environment so as to compete with other regions.

明報社評 2021.06.09:全球迎最低稅率時代 港須加緊提升競爭力

七大工業國集團(G7)達成歷史協議,提倡訂立全球最低企業稅率,暫定至少15%,港府表示將應對全球稅制變化,保持香港競爭力。新經濟時代,跨國巨企利用各地稅率差異,避稅成風,實際繳納稅款低得離譜,全球應當攜手制約。

上世紀末冷戰結束,經濟全球化,各國為了吸引跨國企業落戶,數十年來爭相降低企業稅,互聯網急速發展,亦造就了新經濟的出現,歐美跨國巨企出走避稅成風,發達大國政府流失大量稅收,成為主要輸家,至於大贏家,當然是一眾跨國巨企,以及少數以超低稅率作招徠的國家及地區,諸如愛爾蘭等。在美國,有調查發現,微軟、亞馬遜、facebook、Google母公司Alphabet、Netflix和蘋果公司,過去10年只交了2190億美元稅款,佔它們6萬億美元盈利僅3.6%。以微軟為例,其愛爾蘭子公司並無多少實質業務,去年利潤報稱高達3150億美元,由於公司在百慕達登記,按愛爾蘭法例毋須在當地繳稅;鑑於百慕達亦不設企業稅,微軟這間子公司,實際就是處於稅網之外。

歐美跨國巨企利用各地稅制差異,將高稅率地區的利潤,轉移記帳到低稅區避稅,暴露21世紀全球資本主義體系的不公,國際社會應予制約。美國企業稅率現為21%,拜登政府欲將稅率上調至28%,面對國內很大阻力,未知能否成事。

全球最低稅率頗有事在必行之勢,不排除年底達成協議,香港必須及早做好應變準備。本港現行企業利得稅設計,企業首個200萬港元利潤,稅率為8.25%,200萬港元利潤以上,則以標準稅率16.5%計算,前者主要為中小企而設,未必受全球最低稅率影響,至於16.5%標準稅率,由於高於G7倡議,暫時亦無問題,然而必須指出的是,最低企業稅率是一個複雜課題,很多國家地區為了促進特定產業發展,會給企業提供稅務優惠,影響實際稅率。

全球最低稅率是新事物,具體發展有待觀察。簡單低稅制度,是本港吸引投資的一大賣點,能夠保持固然好,可是依靠低稅率吸引投資的時代,有可能一去不返,當局不能一味吃老本,必須催谷高科技發展,創造更佳的營商環境,去跟其他地區競爭。

■/ Glossary / 生字 /

tax net:the mechanism for ensuring that people and companies pay their taxes

indictment

/ɪnˈdaɪtmənt/

a sign that a system, society, etc. is very bad or very wrong

rein in /reɪn/

to control sth

■英語社評聲檔:link.mingpao.com/53000.htm

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