Is Qualified Refundable Tax Credit So Appealing?—The Nature and the Mechanism of QRTC under Pillar Two  

作　　者：Yifan Zhang 

机构地区：[1]University of Amsterdam

出　　处：《Belt and Road Initiative Tax Journal》2024年第2期98-107,共10页“一带一路”税收(英文)

摘　　要：The concept of the Qualified Refundable Tax Credit (QRTC) is a noveltax term under the OECD's Pillar Two framework, with unique characteristics thatrequire further examination. While some jurisdictions have already adopted treat-ments for QRTC, their implications remain underexplored. This article delves intoQRTC qualitatively and quantitatively. On one hand, the research examines the inter-play between QRTC and existing tax accounting standards, focusing on governmentgrants and income treatment. On the other hand, through quantitative analysis,this article reveals that in general QRTC can offer a more favourable tax outcome formultinational enterprises (MNEs) subject to certain conditions. However, QRTC maynot be beneficial universally, as certain scenarios may diminish its advantageous一such as in the case of companies undergoing mergers and acquisitions (M&A) orfacing a significant recession. The findings suggest that current accounting standardsare insufficient for addressing the unique characteristics of QRTC, necessitating po-tential improvement to tax and accounting regulations. This approach highlights thedistinctive features of QRTC and reveals potential tax competition with respect toQRTC. Practical recommendations for policymakers and businesses are provided tohelp navigate the complexities of the post-Pillar Two tax landscape.

关 键 词：Global minimum tax Pillar Two QRTC Tax credits GloBE income 

分 类 号：R73[医药卫生—肿瘤]