On 19 November 2021, Mr. Wu, Xiaoqiang who was the Director of Hargent Tax International Partner Institute, while he was invited to hold a training on international taxation for Minmetals Development Company Limited, and the tax managers from Minmetals Development headquarters and global branches attended the training online.

This training is focused on five main parts:

(I) Overview of International Taxation. Mr. Wu, Xiaoqiang introduced and explained the principles of international tax jurisdiction, international tax treaties, international tax avoidance and anti-avoidance and non-resident taxation, and integrated the latest cases and common risks of international taxation for Chinese enterprises, starting from the identification of business scenarios of international trade and investment of Chinese enterprises.

(ii) Transfer pricing methods and practices. This part mainly covers the framework of the current international transfer pricing guidelines, comparability analysis, common transfer pricing methods and their application, as well as how to use the transfer pricing guidelines for financial transactions to analyse cross-border related financing transactions of central enterprises, and the impact of the new crown epidemic on transfer pricing in the context of relevant policies.

(iii) Analysis of major overseas country tax regimes. Mr. Wu, Xiaoqiang introduced the latest provisions of the major tax elements of corporate income tax and VAT in Hong Kong, Singapore, the United States, Hong Kong, Australia, Germany, Brazil and other countries, lighted the tax incentives in the relevant countries and explained the tax policies of each country involved in specific businesses of concern to enterprises.

(IV) Frontiers of International Tax Reform. Mr. Wu, Xiaoqiang discussed in depth the possible impact of the latest BEPS 2.0 international tax two-pillar reform new rules on intermediate tier holding parent companies and their member entities, and shared the main directions and methods of response.

(v) Tax allowance in China hot opening regions. This section reviews the tax policies of the four hot open zones, namely Hainan Free Trade Zone, Qianhai Shenzhen-Hong Kong Modern Service Industry Cooperation Zone, Guangdong Hengqin New Area and China (Shanghai) Pilot Free Trade Zone Lingang New Area, and analyses the benefits that can be enjoyed and the scope for operating and investing in them.

The participants reflected that the training was systematic, comprehensive and informative, with both thorough theoretical explanations and real case studies, which were very relevant to the actual operation of enterprises, and the training achieved better results. Through attending this training, enterprises deepened their understanding of the main side contents of international taxation, which helps them prevent tax risks and grasp opportunities in the process of going global, and provides positive guidance and assistance to their international taxation business.

Introduction of Minmetals Development.

Minmetals Development (SH.600058) is a bulk metal and mineral products distribution service provider, mainly engaged in three major types of business: resource trading, metal trading and supply chain services.