财政部 税务总局关于明确资源税有关政策执行口径的公告财政部 税务总局公告2025年第12号

Core Viewpoint - The announcement by the Ministry of Finance and the State Taxation Administration clarifies the execution standards for resource tax policies, effective from December 1, 2025, addressing various issues in tax management and compliance [2][3][4]. Group 1: Tax Exemption and Taxable Products - The announcement specifies situations where resource tax is not applicable, such as products confiscated by administrative bodies and certain construction materials used for backfilling [5][6]. - It details the taxable categories for products like condensate oil and mixed light hydrocarbons extracted from crude oil and natural gas, aligning them with existing tax categories [3][5]. Group 2: Taxable Objects and Definitions - The announcement further clarifies the definitions of taxable objects, including coal, rare earth minerals, and salt products, to reduce disputes between taxpayers and tax authorities [3][6][7]. - It emphasizes the importance of precise definitions for strategic resources to ensure consistent tax application across regions [4][6]. Group 3: Transfer Pricing and Compliance - The announcement outlines acceptable justifications for significantly low transfer prices in related transactions, providing four specific scenarios [3][8]. - Tax authorities are empowered to adjust taxable sales amounts if no valid justification is provided for low pricing in related transactions [8][9]. Group 4: Tax Calculation and Management - The announcement introduces detailed methods for calculating tax exemptions and reductions, including formulas based on production ratios and average sales prices [9][10]. - It mandates that taxpayers maintain proper documentation to support claims for tax exemptions or reductions [10][11]. Group 5: Tax Obligation Timing - The announcement specifies the timing for tax obligations based on various sales methods, ensuring clarity on when tax liabilities arise [12][12]. - It outlines the conditions under which tax obligations are triggered, such as direct payments or credit sales [12][12]. Group 6: Implementation Timeline - The new policies will be implemented starting December 1, 2025, with prior unresolved matters to be handled according to the new guidelines [12].