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.
Extraterritorial enforcement of corporate income tax
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
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