Jurisdictions › China
Consultation

China Pillar Two

Asia-Pacific

IIR
Not adopted
✕ Not adopted
UTPR
Not adopted
✕ Not adopted
QDMTT
Not adopted
✕ Not adopted
In development — This profile is provided for reference only and may contain inaccuracies. Always verify against official legislation and current OECD guidance.
Key implementation point

Under active consultation. China's preferential regime landscape (15% HNTE, 10% SEZ) means QDMTT would be widely applicable if enacted.

Implementation detail
  • 01 China has not enacted Pillar Two legislation as of 2026.
  • 02 China participated in the OECD Inclusive Framework but is proceeding carefully.
  • 03 State Administration of Taxation (SAT) has issued public consultations and study papers on GloBE implementation.
  • 04 China's extensive preferential tax regime (15% high-tech enterprise rate, 10% SEZ rate, R&D super-deduction) would require substantial analysis.
  • 05 If China enacts QDMTT, it would protect Chinese tax base from IIR top-up by other jurisdictions on Chinese entities.
  • 06 China-parented MNE groups: absence of Chinese IIR means other jurisdictions may apply their IIR to non-Chinese low-taxed subsidiaries.
Track China rules against your live MNE

In Pillar2OS you can pull this jurisdiction's rules directly into your entity structure — automatically calculating top-up positions, flagging QDMTT obligations, and tracking rule changes as they happen across all your operating countries.

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