Core Viewpoint - The announcement by the Hainan Provincial Taxation Bureau, Provincial Finance Department, and Market Supervision Administration aims to clarify the substantive operation standards for enterprises in encouraged industries within the Hainan Free Trade Port, promoting high-quality development in the region [1][2]. Group 1: Policy Implementation - The policy execution period is set from January 1, 2025, to December 31, 2027 [1]. - The announcement details the criteria for determining substantive operations, including production and management location, personnel, accounting, and assets [1]. Group 2: Substantive Operation Requirements - In terms of production and operation, enterprises must meet one of two conditions: either have their main production and operation location in the Free Trade Port or have a management institution that exercises substantial control over production and operations located in the Free Trade Port [1]. - For accounting management, enterprises are required to store accounting documents and open basic deposit and main business settlement accounts within the Free Trade Port [2]. - The asset requirements stipulate that necessary production and operation assets must be used within the Free Trade Port, with specific considerations for transportation assets and intangible assets like patents [2].

Core Points - The 2025 Hainan "Double 15" policy is a significant tax incentive for enterprises and high-end talent operating in Hainan, capping corporate and personal income tax rates at 15% [2][7][21] Group 1: Corporate Income Tax Policy - The corporate income tax rate is set at 15% for companies that are registered and substantively operating in Hainan, with a requirement for real office space, employees, and business activities in the region [2][8] - Eligible industries must align with the "Encouraged Industry Directory" for Hainan Free Trade Port, such as tourism, renewable energy, and healthcare [3][10] - The policy is based on the official documents issued by the Ministry of Finance and the State Administration of Taxation, specifically document 财税〔2025〕3号 [3][18] Group 2: Personal Income Tax Policy - The personal income tax rate is also capped at 15% for high-end talent recognized by Hainan's talent management departments or those earning over 300,000 RMB in a tax year [4][11] - Individuals must reside in Hainan for at least 183 days within a tax year, with specific allowances for business trips and training [4][12] - The policy is governed by the document 财税〔2025〕4号, which extends the tax incentives until December 31, 2027 [19][13] Group 3: Key Considerations for Policy Enjoyment - "Substantive operation" is a strict requirement for both enterprises and individuals to qualify for tax benefits, with tax authorities conducting thorough checks [6][14] - Companies must submit a "Substantive Operation Self-Assessment Commitment Form" through the Hainan Electronic Tax Bureau to claim corporate tax benefits [17] - The upcoming full closure of Hainan in 2025 will broaden eligibility for tax incentives, allowing all non-negative list industries to benefit from the 15% corporate tax rate [15][20]