Extraterritorial enforcement of corporate income tax

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clpstaff &clp articles

A tax circular which seeks to strengthen the administration of tax on income derived from equity transfer may have a profound impact on non-resident investors using offshore vehicles. But the authorities have some legal hurdles to clear

Under the current Implementing Regulations for the PRC Enterprise Income Tax Law (中华人民共和国企业所得税法实施条例 ) , effective from January 1 2008, a general anti-avoidance rule (GAAR) was introduced such that arrangements without “reasonable commercial purpose” causing a reduction of taxable gross income will be adjusted. The detailed Implementation Regulations went on further to define this “reasonable commercial purpose” as any arrangement for the primary purpose of the reduction, exemption or deferral of Enterprise Income Tax (EIT) payments.

In the past two years, the State Administration of Taxation (SAT) has issued a number of circulars imposing various tax administrative measures and policies on non-tax-resident enterprises (Non-TRE) with China investments (see Figure 1).

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