Core Viewpoint - The article discusses the tax-related provisions in the "Civil Code of the People's Republic of China," particularly focusing on technology contracts and their implications for taxation [3]. Group 1: Technology Contracts - Article 862 defines technology transfer contracts as agreements where the legal owner of technology transfers specific rights related to patents or trade secrets to another party [6]. - Technology licensing contracts allow the legal owner to permit others to implement or use specific patents or trade secrets [6]. Group 2: Personal Income Tax Law - The "Personal Income Tax Law" and its implementation regulations outline that income from royalties is calculated after deducting 20% of expenses from the total income [7]. - Royalties are defined as income obtained from providing rights to use patents, trademarks, copyrights, and other proprietary rights, excluding manuscript fees [8]. Group 3: Tax Policies for Technology Achievements - The article mentions that cash rewards for technology personnel from the conversion of job-related scientific achievements can be reduced by 50% when calculating their monthly income [8]. - Non-profit research institutions and universities must sign technology contracts and register them according to the "Technology Contract Recognition and Registration Management Measures" [9]. Group 4: Tax Incentives for Equity Incentives and Technology Investment - Individuals or enterprises investing in domestic resident enterprises with technology achievements can choose to defer tax payments until the transfer of equity, allowing for tax deferral policies [10]. - The value of technology achievements can be recorded as an asset for tax deduction purposes when invested in equity [10].

Core Viewpoint - The article discusses various aspects of corporate restructuring, including debt restructuring, equity acquisitions, asset acquisitions, mergers, and corporate splits, emphasizing the tax implications and necessary documentation for each type of restructuring [4][10][13][16]. Debt Restructuring - Debt restructuring refers to the process where creditors agree to modify the terms of a debtor's debt due to financial difficulties faced by the debtor [4]. - Income recognition occurs when the debt restructuring contract or court ruling becomes effective [5]. - Tax treatment involves recognizing debt restructuring income or losses based on the difference between the payment amount and the tax basis of the debt [5][6]. Equity Acquisition - Equity acquisition involves one company purchasing the equity of another to gain control, with payment forms including equity and non-equity payments [7]. - The main parties involved are the acquirer, the transferor, and the target company, with the transferor being the dominant party [8]. - Tax treatment requires the acquirer to recognize the fair value of the acquired equity as the tax basis [9]. Asset Acquisition - Asset acquisition is defined as a transaction where one company purchases the operational assets of another [10]. - The main parties are the acquirer and the transferor, with the transferor being the dominant party [10]. - Tax treatment requires the acquirer to recognize the fair value of the acquired assets as the tax basis [11]. Mergers - A merger involves one or more companies transferring all their assets and liabilities to another existing or newly established company [13]. - The main parties are the merging company, the merged company, and the shareholders of the merged company, with the merged company being the dominant party [13]. - Tax treatment allows the surviving company to continue enjoying tax benefits if the conditions remain unchanged [14]. Corporate Split - A corporate split involves a company transferring part or all of its assets to an existing or newly established company, with shareholders receiving equity or non-equity payments [16]. - The main parties are the splitting company, the split company, and the shareholders of the split company, with the split company being the dominant party [16]. - Tax treatment allows the surviving company to continue enjoying tax benefits if the conditions remain unchanged [16].