Although the Inclusive Framework still has a long way to go to achieve the desired results of the two-pillar solution project, international tax cooperation has proceeded steadily. The fact that almost 150 countries and regions have united in one international body to discuss tax solutions is unprecedented and inspires hope. 

History has taught us that, with or without geopolitical tensions or wars, trade and investment have always found a way to continue. As long as trade and investment persist, international tax matters will remain and continue to arise. 

We are committed to providing a platform to keep up with the pace of international tax development through our annual conference and hope you will gain insight from the topics discussed.

Alternatives to Pillar One 
Pillar One's Amount A, aimed at taxing residual profits of multinational companies, remains contentious, with key nations like the U.S. and China hesitant to act swiftly. Although G20 ministers have reaffirmed commitment to the two-pillar solution, consensus on Pillar One is still lacking. While Pillar Two progresses, some scholars suggest alternative approaches to taxing profits that are not caught under the current international tax rules, questioning the necessity and effectiveness of Amount A, especially given the slow adoption by critical countries.

Advance tax rulings in China
Advance tax rulings offer tax certainty and are valued by taxpayers. China has discussed implementing them and included the concept in its draft Tax Collection Law, though it is not yet enacted. To boost foreign investor confidence, Shanghai's tax authority took the initiative and issued guidance on advance tax rulings in December 2023. The guidance defines rulings for future tax cases but may need further clarification with regard to the realm and other practical issues.

Compliance with Pillar Two in the European Union 
EU Member States were required to implement the Pillar Two Directive by 31 December 2023, affecting multinational companies operating in the EU. These companies must understand the new laws' impact and adjust their tax compliance and global strategies accordingly. The process is complex and time-consuming, as calculating the effective tax rate and top-up tax differs from traditional single-entity profit calculations, making preparation challenging for these organizations.