The 15% global minimum tax (Pillar Two) applies to groups with consolidated revenue above EUR 750 million. Chinese groups above the threshold face top-up taxes in jurisdictions where effective rates fall below 15% — including via HK (8.25% tier) and free-zone entities (0% incentives).
Who is affected: multinational groups (any ownership pattern) with consolidated revenue ≥ EUR 750 million in 2 of the last 4 fiscal years. Key impacts: (1) Hong Kong implemented HKMTT effective 2025 — domestic top-up tax on HK entities of in-scope groups, so the 8.25%/16.5% rates no longer hold for large groups. (2) UAE/Saudi free-zone incentives (0%/special zones) get topped up for in-scope groups. (3) Safe harbours (transition CbCR safe harbour) can simplify 2024-2026 compliance. (4) Subsidiaries below group threshold: unaffected directly — most SME cross-border businesses are NOT in scope, but incentive-dependent planning should anticipate future expansion of scope. Below EUR 750m: optimize normally; above: run a Pillar Two impact assessment before claiming any low-tax incentive.
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