境外投资者以分配利润直接投资暂不征收预提所得税

Core Viewpoint - The article discusses the tax policies encouraging foreign investment in China, specifically focusing on the exemption of withholding income tax for foreign investors reinvesting distributed profits directly into domestic enterprises [2][5]. Group 1: Policy Content - Foreign investors can reinvest profits distributed from Chinese resident enterprises without incurring withholding income tax since January 1, 2018, provided they meet specific conditions [5]. - The scope of direct investment includes non-restricted projects and fields, and can involve actions such as capital increases, new establishments, and equity acquisitions, excluding certain stock purchases [5][6]. - Profits eligible for reinvestment must be actual distributions from retained earnings, such as dividends [5]. Group 2: Applicable Conditions - Non-resident taxpayers are defined as those who qualify as tax residents under tax treaties [3]. - Non-resident taxpayers can self-assess and claim treaty benefits during tax filings, retaining necessary documentation for verification by tax authorities [3][7]. - Required documentation includes proof of tax residency and any agreements or contracts related to the income [7]. Group 3: Policy Basis - The policy is based on the announcement by the State Administration of Taxation regarding the management of treaty benefits for non-resident taxpayers [4][9].