全球最低税：新规则、挑战和东盟的回应

Global Minimum Tax:NewRule,Challenges,andASEAN’s Response Contents Executive Summary3 Introduction4 Channels of Impact Transmission of the GMT7 Measures to Mitigate the Impact of GMTimplementation10 Krungsri Research View12 References13 Unlessexplicitlystatedotherwise,thispublicationandallmaterialthereinisunder the copyright ofKrungsriResearch. As such, the reuse, reproduction, oralteration of this text or any part thereof is absolutely prohibited without priorwrittenconsent.Thisreportdrawsonawiderangeofwell-establishedandtrustworthysources,butKrungsriResearchcanmakenoguaranteeoftheabsolute veracity of the material cited. Moreover,KrungsriResearch will not beheld responsible for any losses that may occur either directly or indirectly fromany use towhich this reportorthe datacontained therein maybe put.Theinformation,opinions,andjudgementsexpressedinthisreportarethoseofKrungsriResearch, but this publication does not necessarily reflect the opinionsof Bank ofAyudhyaPublic Company Limited or of any other companies withinthe same commercial group. This report is an accurate reflection of the thinkingand opinions ofKrungsriResearch as of the day of publication, but we reservethe right to change those opinions without prior notice. For research subscription, contactkrungsri.research@krungsri.com Executive Summary The enforcement of the Global Minimum Tax (GMT) at a rate of 15% will significantly alter the taxcompetition landscape and investment promotion strategies in ASEAN. Tax incentive policies will becomeless effective in attracting foreign direct investment (FDI). However, tax incentives are not the soledeterminant of investment decisions; a country's strong economic fundamentals also play a crucial role.Importantly, as the competitive landscape becomes fairer, the countries that can adapt the fastest will gaina competitive edge. This means that countries that can enhance their foundational factors and createstructural advantages early on will be better positioned to attract investment and strengthen their long-term competitiveness. Meanwhile, countries that continue to rely on tax incentives without adapting oradapting slowly may face a decline in FDI. Therefore, ASEAN member countries must reevaluate their taxincentive structures and adjust their investment promotion strategies to maintain their competitiveness inthis changing tax environment. WanichaDirekudomsak KrittabhornSirichaichingkun Senior Economistwanicha.direkudomsak@krungsri.com+662 2964734 Economistkrittabhorn.sirichaichingkun@krungsri.com+662 296 2968 Introduction The Global Minimum Tax (GMT) is a tax framework applied to Multinational Enterprises (MNEs) to promotefairer global taxation. Its primary objectives are to prevent tax avoidance by multinational enterprises(MNEs) that shift profits to subsidiaries in low-tax jurisdictions, curb the race to the bottom in whichcountries compete for investment by lowering corporate tax rates, and increase global tax revenue toensure fair tax contributions from MNEs. The GMT framework, proposed by theOrganisationfor Economic Cooperation and Development (OECD),requires MNEs whose Ultimate Parent Entity (UPE) has consolidated financial statement revenues of atleast EUR 750 million in at least two out of the past four fiscal years to pay a minimum effective tax rate(ETR) of 15%, regardless of the country in which they operate. Imports of China and the United States and ASEAN's Trading Partner Shares Countries participating in the OECD’s Inclusive Framework on BEPS (IF on BEPS) have begun implementingGMT, including the EU, UK, Canada, Australia, Japan, and South Korea (Figure 2). In ASEAN, seven memberstates have joined the IF on BEPS. Currently, Vietnam, Thailand, Indonesia, Malaysia, and Singapore haveimplemented GMT, while Brunei and the Philippines are in the preparation phase. The implementation of GMT not only impacts the tax management of MNEs but also affects theinternational tax structure(Figure 3). While GMT has a positive effect by redistributing tax revenueamong countries, it may negatively impact developing countries' ability to attract foreign investment.Thisarticle focuses on analyzing the impact of GMT enforcement in ASEAN, specifically in Vietnam, Thailand,Indonesia, Malaysia, and Singapore, which will implement GMT by 2025. It also explores measures eachcountry may take to mitigate these impacts and maintain their long-term attractiveness as investmentdestinations. Channels of Impact Transmission of theGMT The Global Minimum Tax can impact foreign direct investment through multiple channels. Each ASEANcountry experiences varying effects depending on its structural factors, tax policies, andits internaladvantages. Transmission Channels According to the study by the United Nations Conference on Trade and Development (UNCTAD) (2022),the GMT can impact Foreign Direct Investment (FDI) through four main channels, including: 1.Investment Location:Tax rates are a key facto