Cross-border Tax Talks Podcast | CHINA TAX UPDATE: TARIFF TURMOIL AND TREATY TENSIONS | Jenny Chong скачать в хорошем качестве

Cross-border Tax Talks Podcast | CHINA TAX UPDATE: TARIFF TURMOIL AND TREATY TENSIONS | Jenny Chong

Doug McHoney (PwC’s International Tax Services Global Leader) is joined by Jenny Chong, Shanghai-based International Tax Partner and PwC’s Asia-Pacific International Tax Services Leader. Doug and Jenny discuss the structure and enforcement of China’s international tax regime, including corporate tax rates, incentives, CFC rules, and foreign tax credits. They examine the complexities of indirect stock transfer rules, audit trends, and beneficial ownership requirements. The conversation turns to Pillar Two, where Jenny outlines how Chinese multinationals are preparing despite a lack of formal adoption. They also explore the implications of potential termination of the US-China tax treaty and the resurgence of tariffs. Jenny shares how Chinese companies are adapting to compliance burdens and regulatory uncertainty amidst global tax and trade tensions. Timestamps and Descriptions 00:00 - Doug introduces Jenny Chong at PwC’s Asia-Pacific Global Tax Symposium in Singapore 02:55 -Overview of China’s corporate tax system, tax rates, incentives, and withholding taxes 05:25 - China’s foreign tax credit system and comparison to US model 06:25 - China's Controlled Foreign Corporation (CFC) rules and limitations in enforcement 09:00 - Challenges interpreting ‘commercial purpose’ and ‘active income’ under China’s CFC rules 10:00 - Lack of detailed administrative guidance and case law in China’s tax system 12:00 - China’s indirect stock transfer rules and exceptions under Public Notice 7 15:55- Pillar Two: China’s cautious stance and current non-implementation status 17:25 - How Chinese authorities are evaluating Pillar Two’s potential impact 20:25 - Challenges Chinese MNEs face in Pillar Two data collection and compliance 22:30 - Decentralized tax models in China and Japan vs. centralized needs of Pillar Two 24:05 - Concerns over UTPR and China’s low effective tax rate due to incentives 25:10 - Potential suspension of US-China tax treaty: implications and uncertainties 27:00 - PE thresholds and risk of double taxation without treaty protection 28:15 - Withholding tax impact and treaty-shopping considerations 29:45 - US–China investment relationships and high-level political dynamics 30:50 - Trade tensions: recent tariff fluctuations and business impact in China 33:00 - Chinese companies explore supply chain alternatives amid trade uncertainty 34:40 - China audit trends: scrutiny of tax incentives and regional benefits 36:03 - Focus on beneficial ownership, indirect transfers, and restructuring compliance 38:35 - Final reflections on US–China tax dynamics and global uncertainty