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.
See it in the sandbox →