境外投资者以分配利润直接投资税收抵免政策

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图解税收|一图了解境外投资者以分配利润直接投资税收抵免政策
蓝色柳林财税室· 2025-08-04 00:46
Core Viewpoint - The article discusses the new tax credit policy for foreign investors in China, aimed at promoting reinvestment of profits earned by foreign enterprises in the country. This policy will be effective from January 1, 2025, to December 31, 2028, and is designed to enhance the business environment and attract foreign investment [1]. Summary by Sections Policy Overview - The policy allows foreign investors to directly invest their distributed profits in China, with tax credits applicable to certain types of income such as dividends and royalties [3][4]. - The applicable tax rate for dividends and similar income under tax treaties with foreign governments is set at below 10% [3]. Eligibility Criteria - Foreign investors must receive profits from Chinese resident enterprises as retained earnings, which can be reinvested [4]. - Direct investments must include capital increases, new establishments, or equity acquisitions, excluding certain stock purchases [4]. - Investments must be in industries listed in the "Encouraged Foreign Investment Industry Catalog" [5]. - Foreign investors are required to hold their investments for at least 5 years (60 months) to qualify for the tax credit [5]. Investment Recovery and Tax Obligations - After 5 years, if foreign investors withdraw their investments, they must report and pay any deferred taxes on the distributed profits [5]. - If investments are withdrawn before the 5-year period, the tax credits will be adjusted, and any excess credits must be repaid [5]. - The policy allows for tax credits to be carried forward until the balance is exhausted, even after the policy's expiration [6]. Application and Compliance - Foreign investors must provide necessary documentation to the profit-distributing enterprises to benefit from the tax credit [6]. - The profit-distributing enterprises can temporarily refrain from withholding taxes on reinvested profits based on the provided documentation [6]. - Investments made before the policy announcement can apply for retroactive tax credits, but investments prior to January 1, 2025, are not eligible [6].
【轻松办税】已开具的发票如何查询对方是否已抵扣?操作步骤
蓝色柳林财税室· 2025-08-02 09:01
Group 1 - The article provides a guide on how to check whether a client's invoice has been selected for tax deduction through the electronic tax bureau or its app [1][9] - The steps to query invoices include logging into the electronic tax bureau, navigating to the invoice query section, and selecting the appropriate query conditions [1][3] - Users can view detailed information about the invoice status by clicking on the "details" link, which shows the current label information of the selected invoice [3][5] Group 2 - The article emphasizes the importance of understanding tax benefits and ensuring compliance to effectively utilize available tax incentives [14][15] - It discusses the differences in tax treatment for domestic and foreign R&D expenses, highlighting the calculation of deductible amounts for both types [14][17] - The article outlines the process for foreign investors to report reinvestment information and the necessary documentation required for tax credit eligibility [17][20]
国家税务总局关于境外投资者以分配利润直接投资税收抵免政策有关事项的公告国家税务总局公告2025年第18号
蓝色柳林财税室· 2025-08-01 09:20
Core Viewpoint - The announcement by the State Taxation Administration outlines the tax credit policy for foreign investors reinvesting distributed profits directly into domestic enterprises, aiming to encourage foreign investment in China [2][3]. Summary by Sections Section 1: Policy Implementation - Foreign investors using profits to replenish registered capital or increase paid-in capital in domestic enterprises qualify as "new or increased paid-in capital" [3]. - The reinvestment period begins in the month specified in the "Profit Reinvestment Situation Table" issued by the competent commerce department [3]. Section 2: Tax Credit Calculation - Foreign 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 [4]. - If multiple domestic enterprises distribute profits for reinvestment, the tax credit is calculated separately for each enterprise [4]. Section 3: Currency and Reporting - Reinvestments made in currencies other than RMB must be converted to RMB at the exchange rate on the payment date for tax credit calculations [4]. - Foreign investors must submit the "Overseas Investor Reinvestment Tax Credit Information Report" along with the "Profit Reinvestment Situation Table" to the profit distribution enterprise [4][5]. Section 4: Documentation and Compliance - When recovering investments and applying for tax credits, foreign investors must provide specific documentation to the tax authorities [5]. - The tax authorities are required to maintain a record of foreign investors benefiting from the tax credit policy and track compliance [6]. Section 5: Investment Recovery Order - The order of recovering investments involves first disposing of investments that have already enjoyed tax credits, followed by those that meet the conditions but have not yet benefited from the credits [7]. Section 6: Delegation of Authority - Foreign investors and profit distribution enterprises may appoint agents to handle matters related to the announcement, provided written authorization is submitted to the tax authorities [8]. Section 7: Effective Date - The announcement will take effect from January 1, 2025 [9].
国家税务总局发布关于境外投资者以分配利润直接投资税收抵免政策有关事项的公告
Sou Hu Cai Jing· 2025-08-01 01:41
Group 1 - The announcement states that foreign investors using profits to replenish registered capital in domestic resident enterprises, thereby increasing paid-in capital or capital reserves, falls under the category of "new or increased paid-in capital or capital reserves of domestic resident enterprises" [1] - Foreign investors can choose to calculate the tax credit amount based on either 10% of the reinvestment amount or a lower dividend tax rate as stipulated in applicable tax treaties [1] - Once a tax rate is selected, it cannot be changed to a lower rate under tax treaties after holding the investment for 5 years when recovering the investment and declaring deferred taxes [1]
新华财经晚报:AMD计划在许可证获批后恢复MI308产品出货
Xin Hua Cai Jing· 2025-07-16 10:11
Domestic News - The third China International Supply Chain Promotion Expo opened in Beijing, with Vice Premier He Lifeng emphasizing China's role as a key player in global supply chains and its commitment to promoting mutual benefits and cooperation in the industry [1] - The Ministry of Commerce issued a notice to encourage foreign investors to reinvest profits in China through tax incentives, highlighting the importance of stabilizing investment expectations and reducing costs [1] - AMD announced plans to resume shipments of its MI308 products to China once the necessary export licenses are approved, following communication with the U.S. government [2] - Seven major potassium fertilizer distribution companies, including China Agricultural Materials Group, called for increased potassium supply and price reductions to stabilize the market [2] - Huawei regained the top position in China's smartphone market with an approximate 18% share in Q2, while competitors like Vivo and OPPO saw declines [2] International News - European Central Bank board member Nagel stated that a "steady hand" is needed to address uncertainties arising from U.S. tariffs, indicating geopolitical tensions affecting prices [4] - U.K. inflation rate rose to 3.6% in June, exceeding expectations, as the Bank of England predicts inflation may peak at 3.7% in September [4] - In June, foreign investors net sold $2.11 billion in bonds from five Asian countries, marking the first monthly outflow in five months, with Indonesia experiencing the largest outflow [4] Market Overview - The Indonesian central bank cut interest rates by 25 basis points, aligning with expectations of decreasing inflation in 2025 and 2026 [5] - The Shanghai Composite Index closed at 3503.78, down 0.03%, while the Shenzhen Component Index fell 0.22% to 10720.81 [5] - The onshore RMB was at 7.1776, appreciating by 32 points, while the offshore RMB remained stable at 7.1824 [5]
商务部办公厅:做好境外投资者以分配利润直接投资税收抵免政策落实工作
news flash· 2025-07-16 08:33
Core Viewpoint - The Ministry of Commerce has issued a notice regarding the implementation of tax credit policies for foreign investors directly investing through profit distribution [1] Group 1 - Provincial commerce authorities are required to collaborate with finance, taxation, and foreign exchange departments to establish a cross-departmental management service mechanism for tax credit [1] - The notice emphasizes the need for a specific workflow to be developed for the implementation of the tax credit policy [1] - There is a call for enhanced collaboration with market regulation departments to ensure proper qualification review and regulatory responsibilities are fulfilled [1] Group 2 - The notice mandates adherence to information sharing requirements as outlined in Article 6 of the announcement [1]
财政部 税务总局 商务部关于境外投资者以分配利润直接投资税收抵免政策的公告财政部 税务总局 商务部公告2025年第2号
蓝色柳林财税室· 2025-07-09 13:53
Core Viewpoint - The announcement outlines a tax credit policy for foreign investors reinvesting profits distributed by Chinese resident enterprises, effective from January 1, 2025, to December 31, 2028, allowing a 10% tax credit on the reinvestment amount against the annual taxable income of the foreign investor [3][10]. Summary by Sections Tax Credit Policy - Foreign investors can receive a tax credit of 10% on the amount reinvested in China from profits distributed by Chinese resident enterprises during the specified period [3][10]. - If the applicable tax rate under tax treaties with foreign governments is lower than 10%, the treaty rate will apply [3]. Conditions for Eligibility - The profits must be actual distributions from Chinese resident enterprises, classified as dividends or similar equity income [3]. - Eligible reinvestments include capital increases, new establishments, and equity acquisitions, excluding purchases of listed company shares (with some strategic investment exceptions) [3][4]. - The reinvested profits must be in cash or directly transferred assets without intermediary holding [6]. Investment Duration and Compliance - Foreign investors must hold the reinvested assets for at least 5 years (60 months) to qualify for the tax credit [5]. - Upon withdrawal of investments before the 5-year period, investors must pay deferred taxes and may have their tax credit reduced proportionally [7]. Reporting and Verification - Foreign investors must report relevant information through the unified platform managed by the Ministry of Commerce, including details about the reinvestment and the involved enterprises [8]. - Local commerce departments will verify the submitted information and confirm eligibility for the tax credit [8]. Special Conditions - If the invested enterprises undergo restructuring that meets specific criteria, they can continue to enjoy the tax credit [9]. - The policy will be enforced from January 1, 2025, to December 31, 2028, with provisions for any remaining tax credit balances to be utilized until exhausted [10].
境外投资者以分配利润直接投资税收抵免政策出台—— 为投资中国打造更优税收环境
Jing Ji Ri Bao· 2025-07-05 22:12
Core Viewpoint - The announcement by the Ministry of Finance, State Taxation Administration, and Ministry of Commerce introduces tax incentives for foreign investors who reinvest profits distributed by Chinese resident enterprises into domestic direct investments from January 1, 2025, to December 31, 2028, allowing a 10% tax credit against their taxable income for the investment amount [1][3]. Group 1: Policy Details - The new policy allows foreign investors to offset 10% of their taxable income with profits reinvested in eligible domestic projects, which can be carried forward if not fully utilized in the current year [1][3]. - The policy expands the scope of eligible projects for reinvestment, now including all non-prohibited foreign investment projects, enhancing the previous tax exemption policy established in 2018 [1][2]. - To qualify, the profits must be actual distributions from Chinese resident enterprises and used for direct investments such as capital increases, new projects, or equity acquisitions, excluding certain stock purchases [2][3]. Group 2: Investment Conditions - Foreign investors must hold their reinvested profits for at least 5 years (60 months) to benefit from the tax incentives, promoting long-term investment strategies [2][3]. - The reinvestment must be made in cash directly from the profit distribution enterprise to the investment entity, or through the direct transfer of assets in non-cash forms [2]. - If foreign investors withdraw their investments before the 5-year period, they must pay deferred taxes and may have their tax credit reduced proportionally [3].
财政部 税务总局 商务部关于境外投资者以分配利润直接投资税收抵免政策的公告公告2025年第2号
蓝色柳林财税室· 2025-07-05 09:29
Core Viewpoint - The announcement outlines a tax credit policy for foreign investors reinvesting profits distributed by Chinese resident enterprises, effective from January 1, 2025, to December 31, 2028, allowing a 10% tax credit on the reinvestment amount against the annual taxable income of foreign investors [2][7]. Summary by Sections Tax Credit Policy - Foreign investors can offset 10% of their reinvestment amount against their taxable income if the profits are reinvested in eligible domestic investments from January 1, 2025, to December 31, 2028 [2][3]. - If the tax treaty with a foreign government stipulates a lower tax rate on dividends and similar income, that rate will apply [2]. Eligibility Criteria - The profits must be actual distributions from Chinese resident enterprises, classified as dividends or similar equity income [2]. - Eligible reinvestments include capital increases, new establishments, and equity acquisitions, excluding stock purchases of listed companies (with some strategic investment exceptions) [2][3]. - The reinvestment must be in industries listed in the "Encouraged Foreign Investment Industry Catalog" [3]. - Foreign investors must hold the reinvested assets for at least 5 years [3]. Payment and Documentation - Profits used for reinvestment must be paid in cash directly from the profit-distributing enterprise to the invested enterprise, without prior circulation in other accounts [3]. - Documentation must be provided to the profit-distributing enterprise to avoid withholding tax on the reinvested profits [4]. Withdrawal and Tax Obligations - After 5 years, if foreign investors withdraw their investments, they must report and pay any deferred taxes within 7 days [5]. - If investments are withdrawn before 5 years, the tax benefits will be recalibrated, and any excess credits must be repaid [5]. Reporting Requirements - Foreign investors must report their reinvestment details through a unified platform managed by the Ministry of Commerce, including information about the invested enterprises and the amounts involved [5][6]. - The local commerce department will verify the submitted information and report to the provincial level [6]. Special Conditions - If the invested enterprise undergoes a restructuring that meets specific conditions, the tax credit policy can still be applied [6]. Implementation Timeline - The policy is effective from January 1, 2025, to December 31, 2028, with provisions for any remaining tax credits to be utilized until exhausted [7].
境外投资者可按当年投资额10%抵税
Chang Jiang Shang Bao· 2025-07-01 03:37
Core Viewpoint - The Chinese government has introduced a tax credit policy to encourage foreign investors to reinvest profits in domestic enterprises from January 1, 2025, to December 31, 2028, allowing eligible investors to offset 10% of their taxable income against their investment amount [1][2]. Group 1: Policy Details - The new policy allows foreign investors to enjoy tax credits on profits distributed by Chinese resident enterprises, applicable to direct investments such as capital increases, new establishments, and equity acquisitions, excluding certain stock purchases [2]. - The policy requires that the reinvested profits must be retained earnings distributed as dividends or similar equity investment returns, and the investment must be held for at least 5 years [2][3]. - If foreign investors withdraw their investments before the 5-year period, they will lose the tax credit benefits and must repay any deferred taxes [3]. Group 2: Historical Context - This policy builds on a previous initiative from 2017, which exempted foreign investors from withholding income tax on reinvested profits, further promoting foreign investment in China [1].