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境外投资者以分配利润直接投资暂不征收企业所得税政策
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中国明确外资以分配利润直接投资税收抵免政策相关事项
Zhong Guo Xin Wen Wang· 2025-08-01 11:09
Core Points - The announcement from the State Taxation Administration of China clarifies the tax credit policy for foreign investors using distributed profits for direct investment [1] - The policy allows foreign investors to offset 10% of their taxable income for investments made between January 1, 2025, and December 31, 2028, with any unused credits eligible for carryover [1] - The tax credit policy does not affect the existing deferred tax policy for foreign investors [1] Summary by Sections - **Tax Credit Policy**: Foreign investors can use profits distributed by Chinese resident enterprises for direct investment, allowing a 10% tax credit on the investment amount [1] - **Implementation Timeline**: The policy will be effective from January 1, 2025, to December 31, 2028 [1] - **Conditions for Tax Credit**: The policy includes provisions for foreign investors to use profits for capital contributions or increases in paid-in capital, and they can choose to calculate the tax credit based on either the 10% reinvestment amount or a lower dividend tax rate as per applicable tax treaties [1]