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
With new measures allowing overseas private equity players to adopt a new structure for its Rmb funds, authorities have yet to concretely define certain terms of a partnership in order to set a conclusive tax rate