境外投资者以分配利润直接投资税收抵免政策出台

Core Points - The announcement outlines the tax credit policy for foreign investors reinvesting distributed profits in China, effective from January 1, 2025 [5] Group 1: Tax Credit Policy Details - Foreign investors can use profits to replenish registered capital or increase paid-in capital, qualifying as "new or increased paid-in capital" [1] - The reinvestment period begins in the month specified in the "Profit Reinvestment Situation Table" issued by the competent commerce department [2] - Upon reduction, withdrawal, or transfer of equity in the invested enterprise, the holding period for the reinvested amount ceases in the month of equity change or cancellation [3] Group 2: Calculation and Reporting - Investors can choose to calculate the tax credit based on either 10% of the reinvestment amount or a lower dividend tax rate as per applicable tax treaties [2] - Multiple profit distributions from different resident enterprises can be aggregated for tax credit calculations [2] - Reinvestments in currencies other than RMB must be converted to RMB at the exchange rate on the payment date for tax calculations [2] Group 3: Documentation and Compliance - To enjoy the tax credit, foreign investors must submit the "Foreign Investor Reinvestment Tax Credit Information Report" along with the "Profit Reinvestment Situation Table" to the profit distribution enterprise [2] - Upon recovering investments and applying for tax credit, investors must provide specific documentation to the tax authority [3] - Tax authorities are required to maintain records of foreign investors benefiting from the tax credit policy and can request relevant information from involved parties [4]