It's been a busy year for tax authorities in 2010 and next year will be no different. Foreign companies are no longer privy to preferential tax treatments and non-resident enterprises can expect tightening on indirect equity transfers, treaty benefits and transfer pricing audits
The Measures detail the administration of general tax treatment of enterprise re-organisation, the administration of special tax treatment of enterprise re-organisation, and the tax administration of cross-border re-organisation.
The new supplemental enterprise reorganisation tax measures fail to open any new doors for cross-border reorganisations to qualify for special tax treatment. In addition, they still require fine-tuning with numerous details lacking