境外投资者如何以分配利润直接投资税收抵免？

Core Points - The announcement by the Ministry of Finance, State Administration of Taxation, and Ministry of Commerce regarding the tax credit policy for foreign investors reinvesting distributed profits remains effective, allowing for deferred tax payment on eligible reinvestments [2][3]. Group 1: Tax Credit Policy - The deferred tax policy allows foreign investors to reinvest profits distributed from Chinese resident enterprises into non-restricted foreign investment projects without incurring withholding income tax [2]. - When calculating the tax credit amount for reinvestment, foreign investors can choose between a 10% rate or a lower rate specified in applicable tax treaties [3][5]. - An example illustrates that if a foreign company receives a profit of 10 million yuan and reinvests it, it can choose to apply either a 10% or a 5% tax rate for calculating the tax credit [4][5]. Group 2: Tax Credit Adjustment - If a foreign investor does not meet the conditions for enjoying the tax credit policy, the tax credit amount must be adjusted accordingly [8]. - An example shows that if a foreign investor recovers part of their investment before five years, they must adjust their tax credit amount and pay the corresponding deferred tax [8][13]. - The order of recovering investments is specified, prioritizing those that have enjoyed the tax credit policy [15][22]. Group 3: Currency and Tax Reporting - For reinvestments made in currencies other than RMB, the amount must be converted to RMB using the exchange rate on the payment date to calculate the deferred tax and tax credit [7]. - Foreign investors must submit specific tax forms when recovering investments, detailing the tax credit and any taxes owed [9][14].