大灣區香港企業稅優惠

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Greater Bay Area's Strategic Role in China's Economy

The Guangdong-Hong Kong-Macao Greater Bay Area (GBA) initiative stands as a cornerstone of China's economic strategy, designed to integrate nine cities in Guangdong province with the two Special Administrative Regions of Hong Kong and Macao. Adopted on February 18, 2019, the Outline Development Plan for the GBA aims to create a world-class city cluster rivaling other major bay areas globally.

With less than one percent of China's land space, the Greater Bay Area contributed approximately 11 percent of China's economy as of 2023. The region covers around 56,100 square kilometers and is home to nearly 87 million people. This concentration of economic activity makes the GBA a critical testing ground for innovative tax policies designed to attract talent and investment from Hong Kong and abroad.

The Nine Mainland Cities

The GBA encompasses nine municipalities in Guangdong province, each with distinct economic strengths:

• Guangzhou: Capital of Guangdong province, focusing on manufacturing, financial services, automotive, and petrochemical sectors
• Shenzhen: Known as China's Silicon Valley, home to prominent technology companies and innovation hubs including Qianhai special zone
• Zhuhai: Borders Macao and houses the Hengqin Cooperation Zone, connected via the Hong Kong-Zhuhai-Macao Bridge
• Foshan: Manufacturing hub with focus on traditional industries and emerging technologies
• Dongguan: "World Factory" positioned between Guangzhou and Shenzhen, transitioning from manufacturing to services
• Zhongshan: Industrial city with balanced economic development
• Jiangmen: Emerging industrial and logistics center
• Huizhou: Center of Hakka culture and manufacturing
• Zhaoqing: Western gateway of the GBA with growing industrial base

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Individual Income Tax (IIT) Subsidy Program

On March 14, 2019, the Ministry of Finance and the State Administration of Taxation jointly issued the "Notice on Preferential Individual Income Tax Policies in the GBA Area" (Circular 31), establishing a groundbreaking tax subsidy program for overseas talent, including Hong Kong residents.

How the 15% IIT Cap Works

The subsidy program reduces the effective individual income tax rate for qualified foreign talent to 15% of taxable income. This represents a significant benefit compared to China's standard progressive IIT rates, which range from 3% to 45% depending on income levels, with the top rate applying to annual income exceeding RMB 960,000.

The mechanism works as follows:

1. Qualified individuals pay their regular IIT in accordance with Chinese tax law at the progressive rates
2. They then receive a subsidy equal to the difference between the actual IIT paid and 15% of their taxable income
3. The subsidy is granted by the Municipal People's Government and is itself exempt from individual income tax
4. The subsidy is calculated on a consolidated basis for all taxable income and paid once annually

Example: A Hong Kong professional working in Shenzhen with annual taxable income of RMB 1,200,000 would normally pay approximately RMB 255,000 in IIT under progressive rates. With the subsidy, their effective tax is capped at RMB 180,000 (15% of RMB 1,200,000), resulting in a subsidy of RMB 75,000.

Eligibility Requirements for Hong Kong Residents

To qualify for the IIT subsidy, Hong Kong individuals must meet specific identity and professional criteria:

Identity Requirements (any one of the following):

• Permanent resident of Hong Kong, Macao, or Taiwan
• Hong Kong resident eligible for the Hong Kong Immigration Scheme (for talented individuals, professionals, and entrepreneurs)
• Overseas Chinese with long-term residence abroad
• Foreign nationality holder
• Returned overseas student

Professional Requirements:

Applicants must be recognized as "high-end talent" or "talent in short supply" under criteria established by each municipal government. This typically includes:

• Participants in major national, provincial, or municipal talent projects
• Holders of Guangdong "Talent Excellent Guangdong Card"
• Holders of foreigner work permit (Class A) or foreign high-end talent confirmation letter
• Professionals in encouraged industries such as technology, finance, modern services, scientific research, marine science, intelligent manufacturing, and digital industries

Operational Requirements:

• Work in one of the nine GBA cities
• Pay taxes in accordance with Chinese law
• Comply with laws, regulations, scientific research ethics, and integrity standards
• Maintain valid identity documents throughout the tax year (January 1 to December 31)

Application Process and Deadlines

The IIT subsidy application process is administered separately by each city, with varying timelines and requirements. Applications are processed only once per year, so missing the deadline requires waiting until the following year.

Shenzhen Application Timeline (2025):

Period	Dates	Details
Tax Year Covered	January 1 - December 31, 2024	Period for which subsidy is calculated
Application Window	June 1 - July 31, 2025	Submit application and supporting documents
Employer Review Deadline	By July 31, 2025	Employer verification and submission

Guangzhou Application Timeline (2025):

Period	Dates	Details
Tax Years Covered	2023 and 2024	Applications for both years accepted
Application Window	August 20 - October 20, 2025	Submit application and supporting documents

Required Documents:

• Identity documents (Hong Kong ID, passport, visa, Hong Kong/Macao/Taiwan permits)
• Proof of talent status (certificates, confirmation letters, talent program documentation)
• Individual income tax payment records for the relevant tax year
• Employment contract or proof of employment in the GBA
• Signed commitment letter (template provided by local authorities)
• Employer verification and written statement

Application Steps:

1. Register on the platform: Access the Guangdong Government Service Network and search for "High-end and Shortage Overseas Talent Individual Income Tax Subsidy" for your specific city
2. Prepare documents: Gather all required identity, talent status, and tax payment documentation
3. Submit application: Complete the online application form and upload supporting documents
4. Employer review: Your employer must review, verify, and submit the application through the designated system
5. Government review: Local tax and talent authorities review applications
6. Subsidy payment: Approved subsidies are paid directly to qualified applicants

Subsidy Cap and Tax Treatment

The IIT subsidy is capped at RMB 5 million (approximately US$690,000) per taxpayer for each tax year. Importantly, the subsidy itself is exempt from individual income tax in the hands of the recipient, ensuring that the full benefit is realized without additional tax burden.

Program Extension Through 2027

On August 25, 2023, the Ministry of Finance issued the Circular on Continuing the Preferential Individual Income Tax Policies in the GBA, extending the IIT subsidy program until December 31, 2027. This extension provides certainty for Hong Kong professionals considering relocation or cross-border work arrangements and demonstrates the government's continued commitment to attracting and retaining foreign talent in the region.

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Corporate Income Tax Incentives in Special Zones

Beyond individual tax benefits, the GBA offers substantial corporate income tax incentives in three designated special zones: Qianhai (Shenzhen), Hengqin (Zhuhai), and Nansha (Guangzhou). These zones are designed to attract specific industries aligned with China's economic development priorities.

15% Corporate Tax Rate vs. 25% Standard Rate

Qualified enterprises operating in these zones benefit from a preferential corporate income tax (CIT) rate of 15%, compared to China's standard CIT rate of 25%. This represents a 40% reduction in tax liability and positions these zones competitively with Hong Kong's corporate tax rate of 8.25% (first HK$2 million) and 16.5% (above HK$2 million).

Qianhai Shenzhen-Hong Kong Modern Services Cooperation Zone

Located in Shenzhen and strategically positioned adjacent to Hong Kong, Qianhai serves as a critical bridge for Hong Kong-Mainland economic integration.

Validity Period:

From January 1, 2014 to December 31, 2025 (extended by Notice issued July 9, 2021)

Encouraged Industries:

• Modern logistics services
• Information and technological services
• Financial services
• Professional services
• Innovation and technology enterprises

Key Features for Hong Kong Companies:

• Proximity to Hong Kong enabling easy cross-border operations
• Special arrangements allowing "Hong Kong Capital, Hong Kong Law" and "Hong Kong Capital, Hong Kong Arbitration" frameworks
• Exemption from individual income tax for Hong Kong residents on amounts exceeding their Hong Kong tax burden (effective January 1, 2023 to December 31, 2027)
• One-time subsidies up to HK$30 million for qualifying new businesses in preferred sectors
• Rental subsidies covering up to 50% of rent for eligible enterprises

Hengqin Guangdong-Macao Intensive Cooperation Zone

Located in Zhuhai and bordering Macao, Hengqin focuses on Guangdong-Macao cooperation while offering opportunities for Hong Kong enterprises.

Validity Period:

Effective from January 1, 2021 (ongoing, extended from earlier policies dating to 2013)

Encouraged Industries:

• Scientific and technological research and high-end manufacturing
• Traditional Chinese medicine
• Cultural tourism, convention and exhibition services
• Commercial and trade industries
• Financial services

Key Features:

• Low barriers and fewer limits for offshore funds to enter Hengqin
• Accelerated roll-out of preferential tax systems and streamlined application procedures
• Strategic location connected to Hong Kong via the Hong Kong-Zhuhai-Macao Bridge
• Focus on integration with Macao while remaining accessible to Hong Kong investors

Nansha New Area (Guangzhou)

Located in Guangzhou, Nansha serves as a strategic gateway combining maritime advantages with technological innovation.

Validity Period:

From January 1, 2022 to December 31, 2026

Geographic Scope:

Applies only to "initial launch areas" covering 23 square kilometers, including:

• Nansha Bay area of the Guangdong Pilot Free Trade Zone
• Qingsheng Hub Cluster
• Nansha Hub Cluster

Encouraged Industries:

• Fundamental and applied research
• Marine science and technology
• Intelligent manufacturing
• Digital industries

Special Benefits:

• Extended loss carry-forward period of 13 years for qualified enterprises (vs. standard periods)
• Preferential IIT treatment for Hong Kong and Macau residents, bringing after-tax income in line with what they would obtain in Hong Kong/Macau
• Continued availability of IIT incentive policy for foreign talent from all countries

Eligibility Requirements for 15% CIT Rate

To qualify for the preferential 15% corporate income tax rate, enterprises must demonstrate "substantial operations" in the respective zones. While specific requirements vary slightly by location, the core criteria include:

Registration and Industry:

• Registered as a resident enterprise in the respective special zone
• Engaged in eligible industrial projects listed in the zone's encouraged industry catalogue
• Can refer to the 2021 Version of the Catalogue for Encouraged Industries Eligible for CIT Preferential Treatment

Substance Requirements:

• Production, operation, personnel, accounts, and property located in the respective zone
• Revenue from main businesses must constitute at least 70% of the enterprise's overall revenue
• Actual operational presence with genuine business activities (not merely a registered address)

Documentation:

• Submission of Substantive Operation Self-Assessment Commitment Form
• Declaration indicating compliance with each eligibility requirement
• Supporting documentation demonstrating operational substance

Approval Process:

For Qianhai, companies meeting the criteria can immediately enjoy the preferential tax rate without requiring separate approval, simplifying the administrative burden.

Comparison of Special Zone Benefits

Zone	Location	CIT Rate	Valid Until	Key Industries
Qianhai	Shenzhen	15%	Dec 31, 2025	Modern services, tech, finance
Hengqin	Zhuhai	15%	Ongoing	R&D, traditional Chinese medicine, tourism
Nansha	Guangzhou	15%	Dec 31, 2026	Research, marine tech, smart manufacturing

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Cross-Border Tax Arrangements and Coordination

The success of GBA tax incentives depends on effective cross-border coordination between Hong Kong and Mainland tax authorities. Recent developments have strengthened this cooperation framework.

September 2024 Tax Cooperation Memorandum

On September 24, 2024, at the Fifth Belt and Road Initiative Tax Administration Cooperation Forum held in Hong Kong, tax authorities from Guangdong province, Shenzhen municipality, Hong Kong, and Macao signed a memorandum of understanding (MOU). This landmark agreement established a framework for:

• Enhanced communication and cooperation between jurisdictions
• More effective resolution of cross-border tax issues for taxpayers operating in the GBA
• Streamlined processes for addressing tax disputes
• Coordinated implementation of tax incentive programs
• Information sharing within legal frameworks

Hong Kong-Mainland Double Taxation Arrangement

Hong Kong and Mainland China maintain a comprehensive Double Taxation Arrangement (DTA), with the Fifth Protocol effective since January 1, 2020 in Mainland China and April 1, 2020 in Hong Kong. The DTA is critical for GBA operations, providing:

Withholding Tax Reductions:

Payment Type	Standard Rate	DTA Rate (with Tax Residency Certificate)	Savings
Dividends	10%	5%	50% reduction
Interest	10%	7%	30% reduction
Royalties	10%	7%	30% reduction

Permanent Establishment Rules:

The DTA provides clear definitions and thresholds for what constitutes a permanent establishment, helping Hong Kong firms avoid unintended tax exposure in the Mainland.

Mutual Agreement Procedure (MAP):

The DTA includes a MAP mechanism for resolving cross-border tax disputes, with the first successful Hong Kong-Mainland MAP case concluded in late 2023.

Tax Residency Certificate Application

Hong Kong companies and individuals can apply to the Hong Kong Inland Revenue Department for a Tax Residency Certificate. This certificate:

• Enables access to reduced withholding tax rates under the DTA
• Simplifies cross-border capital flows with regions having foreign exchange controls
• Facilitates international fund transfers and payments for GBA operations
• Should be obtained well in advance of planned distributions (process can take several weeks)

Challenges in Cross-Border Tax Compliance

Despite coordination efforts, Hong Kong firms operating in the GBA still face several tax challenges:

Tax Rate Differentials:

Even with the 15% preferential rates in special zones, a rate differential exists compared to Hong Kong's 8.25%/16.5% two-tiered profits tax. Additionally, companies may face unrecoverable costs including penalties, interest charges, and secondary adjustments.

Transfer Pricing Scrutiny:

Cross-border transactions between Hong Kong entities and GBA subsidiaries face enhanced transfer pricing scrutiny from both jurisdictions. Companies must maintain robust documentation supporting arm's length pricing.

Value Added Tax (VAT):

Hong Kong has no VAT, while Mainland China applies VAT at rates of 6%, 9%, or 13% depending on the category. This creates complexity in pricing and compliance for cross-border transactions.

Social Insurance Contributions:

Mainland China requires employer and employee social insurance contributions, which do not exist in Hong Kong's tax system. Hong Kong residents working in the GBA must factor these additional costs into their compensation planning.

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Strategic Planning for Hong Kong Firms

To maximize the benefits of GBA tax incentives while maintaining compliance, Hong Kong firms should consider the following strategic approaches:

Entity Structure Optimization

Special Zone Subsidiary:

Establish a wholly-owned subsidiary or joint venture in Qianhai, Hengqin, or Nansha to access the 15% CIT rate. Ensure the subsidiary meets substance requirements with genuine operational activities, staff, and decision-making authority.

Industry Alignment:

Structure operations to align with encouraged industries in each zone. Review the Catalogue for Encouraged Industries to ensure eligibility and maximize the 70% revenue threshold from encouraged activities.

Holding Company Considerations:

Use a Hong Kong holding company to coordinate GBA operations, benefiting from Hong Kong's territorial tax system, DTA network, and reputation as an international financial center.

Individual Tax Planning for Employees

IIT Subsidy Eligibility:

For Hong Kong employees relocating to or working in the GBA, ensure they qualify as "high-end talent" or "talent in short supply" to access the 15% IIT cap. Obtain necessary talent program certifications or confirmations before the tax year begins.

Cross-Border Employment Structures:

Consider whether employees should be employed by the Hong Kong entity with secondment to GBA, or directly employed by the GBA entity. Each structure has different tax implications for both employer and employee.

Application Timing:

Plan for annual IIT subsidy applications with strict deadlines. Missing the application window means waiting an entire additional year for the benefit.

Transfer Pricing and Documentation

Arm's Length Pricing:

Establish transfer pricing policies for transactions between Hong Kong entities and GBA subsidiaries based on thorough functional analysis, comparability studies, and economic substance.

Advance Pricing Arrangements:

For significant or complex cross-border transactions, consider seeking advance pricing arrangements (APAs) with tax authorities to provide certainty and reduce audit risk.

Documentation Standards:

Maintain contemporaneous transfer pricing documentation meeting both Hong Kong and Mainland China requirements, including master files, local files, and functional analysis supporting profit allocation.

Withholding Tax Management

Tax Residency Certificate:

Apply for Hong Kong Tax Residency Certificates before making dividend distributions, interest payments, or royalty payments from GBA subsidiaries to Hong Kong parent companies to access reduced 5%/7% DTA rates.

Payment Structuring:

Structure cross-border payments to optimize tax efficiency, considering the interplay of withholding taxes, foreign exchange controls, and commercial requirements. Service fees, royalties, interest, and dividends each have different tax treatments.

Compliance Calendar

Hong Kong firms operating in the GBA should maintain a comprehensive compliance calendar:

Period	Action Item	Jurisdiction
January-March	Annual IIT final settlement for employees	Mainland GBA
May	Corporate income tax annual filing (Mainland)	Mainland GBA
June-July	IIT subsidy application (Shenzhen)	Mainland GBA
August-October	IIT subsidy application (Guangzhou)	Mainland GBA
Ongoing	Monthly VAT and IIT withholding filing	Mainland GBA
April/May	Hong Kong profits tax return filing	Hong Kong
As needed	Tax Residency Certificate application	Hong Kong

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Recent Policy Updates and Developments (2024-2025)

Hong Kong's 2024 Policy Address on GBA Integration

On October 16, 2024, Hong Kong's Chief Executive delivered the 2024 Policy Address in the Legislative Council, emphasizing deeper collaboration with the Greater Bay Area. Key measures include:

• Enhanced support for Hong Kong businesses expanding into the GBA
• Promotion of innovation and technology sector development with GBA linkages
• Strengthened financial services integration between Hong Kong and GBA markets
• Digital economy initiatives facilitating cross-border operations
• Establishment of the Greater Bay Area International Clinical Trial Institute in Hetao
• Setup of AI Supercomputing Centre to support tech development
• Development of the Greater Bay Area Clinical Trial Collaboration Platform
• Extension of pilot arrangement for graduates from GBA campuses of Hong Kong universities to work in Hong Kong for two years

Hong Kong Global Minimum Tax Implementation (2025)

The Inland Revenue (Amendment) (Minimum Tax for Multinational Enterprise Groups) Ordinance 2025 was gazetted on June 6, 2025, implementing OECD's BEPS 2.0 Pillar Two. This affects large Hong Kong firms operating in the GBA:

Key Provisions:

• Applies to multinational enterprise (MNE) groups with annual consolidated revenue of at least EUR 750 million
• Implements Income Inclusion Rule (IIR) and Undertaxed Profits Rule (UTPR)
• Introduces Hong Kong Minimum Top-up Tax (HKMTT) ensuring 15% effective tax rate
• Effective for fiscal years beginning on or after January 1, 2025
• Investment funds and insurance businesses exempt from HKMTT

Impact on GBA Operations:

Large MNE groups with GBA subsidiaries benefiting from 15% preferential CIT rates may need to calculate jurisdiction-specific effective tax rates. If the effective rate in a GBA jurisdiction falls below 15% due to various deductions and incentives, top-up tax may be required. Careful planning is needed to assess the interaction between GBA incentives and global minimum tax rules.

Extension of GBA IIT Subsidy Through 2027

On August 25, 2023, the Ministry of Finance issued the Circular on Continuing the Preferential Individual Income Tax Policies in the GBA, extending the individual income tax subsidy program until December 31, 2027. This extension ensures stability and predictability for individuals planning long-term career moves to the region.

Qianhai Special IIT Policy for Hong Kong Residents

A new Notice effective January 1, 2023 and valid until December 31, 2027 provides that Hong Kong residents working in the Qianhai Cooperation Zone will be exempt from paying the portion of their individual income tax that exceeds the tax burden they would face in Hong Kong. This goes beyond the 15% cap, potentially providing even greater benefits for certain Hong Kong residents. Importantly, Hong Kong residents can choose to enjoy either the Qianhai IIT exemption or the GBA-wide IIT subsidy, but not both concurrently.

Hong Kong Two-Tiered Standard Rates (2024/25)

Starting from the year of assessment 2024/25, Hong Kong introduced a two-tiered standard rates regime for salaries tax and tax under personal assessment:

• First HK$5,000,000 taxed at 15%
• Remainder taxed at 16%
• Taxpayers taxed at progressive rates unaffected

This change impacts the tax burden comparison between Hong Kong and the GBA for high-income earners, potentially making the GBA subsidy program even more attractive for certain individuals.

Enhanced Cross-Border Tax Coordination (2024)

The September 24, 2024 MOU between tax authorities from Guangdong, Shenzhen, Hong Kong, and Macao marks a significant step toward seamless tax administration in the GBA. Expected benefits include:

• Faster resolution of cross-border tax disputes
• More consistent interpretation of tax incentive programs
• Improved information exchange within legal frameworks
• Streamlined procedures for taxpayers operating across jurisdictions

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Practical Considerations and Common Pitfalls

Substance Requirements

Pitfall: Establishing a GBA entity solely to access the 15% CIT rate without genuine operational substance.

Solution: Ensure the GBA entity has real business activities, qualified employees, decision-making authority, and generates at least 70% of revenue from encouraged industries. Tax authorities increasingly scrutinize substance, and failure to meet requirements can result in denial of preferential rates and penalties.

IIT Subsidy Application Timing

Pitfall: Missing the annual application window for IIT subsidies, which only occur once per year.

Solution: Establish a comprehensive calendar for each GBA city where employees work. Begin preparing documentation well in advance of application periods. Coordinate with employers to ensure timely review and submission.

Tax Residency Certificate Delays

Pitfall: Attempting to obtain Tax Residency Certificate at the last minute before making cross-border payments, resulting in delays and higher withholding tax rates.

Solution: Apply for Tax Residency Certificates from Hong Kong IRD several weeks before planned dividend distributions, interest payments, or royalty payments. The application process requires time for processing and documentation verification.

Misunderstanding Zone-Specific Requirements

Pitfall: Assuming that all GBA tax incentives apply uniformly across all nine cities and all special zones.

Solution: Carefully review the specific requirements, encouraged industries, and geographic limitations for each zone. For example, Nansha's 15% CIT rate only applies to the 23 square kilometer "initial launch areas," not the entire Nansha district.

Inadequate Transfer Pricing Documentation

Pitfall: Failing to maintain contemporaneous transfer pricing documentation for cross-border transactions between Hong Kong and GBA entities.

Solution: Implement robust transfer pricing policies from the outset. Maintain master files, local files, and functional analyses supporting arm's length pricing. Update documentation annually to reflect changes in business operations and market conditions.

Overlooking VAT Implications

Pitfall: Focusing solely on income tax incentives while overlooking VAT obligations in the Mainland (Hong Kong has no VAT).

Solution: Factor VAT implications into pricing, contract structures, and financial projections. Understand whether services or goods provided qualify for 6%, 9%, or 13% VAT rates, and structure transactions to optimize VAT efficiency where legally permissible.

Social Insurance Contributions

Pitfall: Failing to budget for mandatory employer and employee social insurance contributions in the Mainland.

Solution: Incorporate social insurance costs into employment budgets and compensation packages. Understand that total employment costs in the GBA will exceed salary due to these mandatory contributions, which can represent 30-40% of salary for combined employer and employee portions.

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Future Outlook and Trends

Continued Integration and Liberalization

The GBA initiative represents a long-term strategic priority for China. Expected developments include:

• Further expansion of encouraged industries eligible for preferential tax treatment
• Additional liberalization measures under CEPA framework
• Potential extension of CIT incentive validity periods beyond current deadlines
• Enhanced cross-border financial infrastructure facilitating capital flows
• Streamlined administrative procedures reducing compliance burden

Technology and Innovation Focus

All three special zones emphasize technology, innovation, and advanced services—sectors where Hong Kong firms have competitive advantages. The government is likely to introduce additional targeted incentives for:

• Artificial intelligence and machine learning
• Biotechnology and life sciences
• Fintech and digital finance
• Green technology and sustainable development
• Advanced manufacturing and Industry 4.0

Talent Mobility

Facilitating cross-border talent movement remains a priority. Future developments may include:

• Simplified visa and work permit procedures for Hong Kong residents
• Mutual recognition of professional qualifications across more sectors
• Coordination of social insurance and pension schemes
• Enhanced tax coordination reducing compliance complexity for individuals working across jurisdictions

Global Minimum Tax Adaptation

As the global minimum tax regime takes effect, the GBA incentive structure may evolve to maintain competitiveness while complying with international standards. This could include:

• Shifting from rate-based incentives to qualified refundable tax credits (which don't reduce effective tax rates under Pillar Two calculations)
• Enhanced incentives for R&D and innovation through super-deductions
• Focus on non-tax incentives such as subsidies, grants, and infrastructure support