国家税务总局发布关于境外投资者以分配利润直接投资税收抵免政策有关事项的公告

Group 1 - The announcement states that foreign investors using profits to replenish registered capital in domestic resident enterprises, thereby increasing paid-in capital or capital reserves, falls under the category of "new or increased paid-in capital or capital reserves of domestic resident enterprises" [1] - Foreign investors can choose to calculate the tax credit amount based on either 10% of the reinvestment amount or a lower dividend tax rate as stipulated in applicable tax treaties [1] - Once a tax rate is selected, it cannot be changed to a lower rate under tax treaties after holding the investment for 5 years when recovering the investment and declaring deferred taxes [1]