国家税务总局：境外投资者再投资时，区分两种情形计算税收抵免额度

Core Points - The announcement outlines a tax credit policy for foreign investors reinvesting profits, allowing them to defer corporate income tax while enjoying a temporary tax incentive [1][23][26] - The policy is effective from January 1, 2025, and will remain in place until December 31, 2028, with provisions for any remaining credits to be utilized thereafter [20][26] Group 1: Tax Credit Policy Overview - The tax credit policy provides a temporary tax incentive for foreign investors reinvesting profits, allowing them to defer corporate income tax [1][23] - Foreign investors can choose to calculate the tax credit based on either 10% of the reinvestment amount or a lower dividend withholding tax rate as per applicable tax treaties [3][24] - The policy does not affect the existing deferred tax policies, which remain applicable [1][2] Group 2: Reinvestment Timeframe - The reinvestment period for foreign investors begins from the month specified in the "Profit Reinvestment Situation Table" issued by the business authority [2][23] - The holding period for the reinvestment must be at least five years (60 months) to qualify for the tax credit [2][6] Group 3: Calculation of Tax Credit Amount - The tax credit amount can be calculated based on the reinvestment amount, with options to select a 10% rate or a lower rate from tax treaties [3][24] - If a foreign investor has multiple reinvestments, the tax credit must be aggregated by the profit distribution enterprise [3][24] Group 4: Adjustments and Compliance - If a foreign investor does not meet the conditions for the tax credit, adjustments to the tax credit amount will be required [6][26] - Foreign investors must submit specific documentation to the tax authorities when claiming the tax credit or making tax payments [25][26] Group 5: Handling of Tax Credits Post-2028 - Any remaining tax credit balances after December 31, 2028, can still be utilized until fully exhausted [20][26] - Foreign investors can apply for retroactive tax credits for eligible investments made between January 1, 2025, and the announcement date [21][26]