税收抵免政策是给予境外投资者再投资的阶段性税收优惠，境外投资者享受税收抵免政策的，仍可享受 递延纳税政策。 8月1日，根据《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》 （2025年第2号，以下简称财税公告），国家税务总局发布了《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》（2025年第18号，以下简称征管公告）。现就境外投资者以 分配利润直接投资税收抵免政策（以下简称税收抵免政策）有关执行问题解读如下： 一、在财税公告和征管公告出台后，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（以下简 称递延纳税政策）是否依然有效？ 征管公告不影响递延纳税政策的效力，递延纳税政策相关文件继续适用。税收抵免政策是给予境外投资 者再投资的阶段性税收优惠，境外投资者享受税收抵免政策的，仍可享受递延纳税政策。 二、如何理解"境外投资者持有再投资的时间"? 境外投资者以商务主管部门出具的《利润再投资情况表》中列明的再投资时间当月，确认开始计算其持 有再投资的时间，以收回投资款与被投资企业按规定完成法律形式变更手续月份中较早的月份，作为停 止计算境外投资者持有再投资 ...

Core Viewpoint - The Chinese government has introduced a series of measures to encourage foreign direct investment (FDI) and reinvestment in response to the declining global FDI and increasing uncertainties in the international economic environment [1][8]. Summary by Relevant Sections Encouragement of Reinvestment - The new measures aim to promote reinvestment by foreign enterprises in China, allowing them to use profits earned in China for additional investments or new projects [1]. - The National Development and Reform Commission (NDRC) emphasizes the importance of reinvestment as a key aspect of stabilizing foreign investment [1]. Tax Incentives - A new tax credit policy has been introduced, allowing foreign investors to offset 10% of their investment amount against their taxable income for reinvestments made between January 1, 2025, and December 31, 2028 [2][3]. - The existing "deferred tax" policy has been in place since 2018, which allows foreign investors to postpone tax payments on reinvested profits, with reinvestment amounts reaching 162.28 billion yuan in 2024, a 15% increase year-on-year [2][4]. Policy Framework - The new tax credit mechanism builds on the deferred tax policy, providing clearer tax asset allocations and allowing for carryover of unused credits to future years [4]. - The policy encourages long-term investment commitments by imposing additional tax costs for short-term withdrawals, with a five-year holding requirement for the tax credit to remain valid [4]. Comprehensive Support Measures - The notification includes various support policies such as optimizing land use, simplifying administrative processes, facilitating foreign exchange fund usage, and increasing financial support for foreign investment [6]. - Specific measures include flexible land leasing options and streamlined processes for foreign enterprises establishing new entities in China [6]. Positive Impact on Employment and Economy - The cumulative number of foreign-invested enterprises in China is expected to exceed 1.239 million by the end of 2024, with reinvestment contributing to new production capacities, job creation, and tax revenue [7]. - The series of policies is seen as a comprehensive approach to encourage both new and reinvested foreign investments, enhancing the overall business environment in China [7][8].

Group 1 - China's Ministry of Commerce issued a notice to encourage foreign investors to increase their investments in China through a tax credit policy for profit reinvestment, highlighting the importance of tax incentives in stabilizing investment expectations and reducing costs [2] - The National Energy Administration reported that the national maximum electricity load reached a record high of 1.506 billion kilowatts, an increase of 0.055 billion kilowatts compared to the previous year, indicating a critical period for energy supply during the summer peak [3] - Seven major potassium fertilizer distribution companies in China jointly announced an initiative to increase potassium fertilizer supply and reduce prices, aiming to stabilize market expectations and return prices to reasonable levels [4] Group 2 - The Ministry of Industry and Information Technology released a new product announcement list that includes Tesla's six-seat Model Y L [5] - Postal Savings Bank plans to invest 10 billion yuan to establish China Post Financial Asset Investment Co., Ltd [5] - Jinggong Steel Structure signed a contract for a 550 million yuan project in Jeddah, Saudi Arabia, which will be used for the FIFA World Cup events [5] Group 3 - Shanghai Material Trade Company experienced a four-day stock price increase, stating that there have been no significant changes in its fundamentals [6] - Guangsheng Tang's GST-HG131 has been included in the list of breakthrough therapy designations by the drug review center, although this does not guarantee market approval [6] - Medike's plan to acquire 100% of Haisholi and INNOWAVE VIETNAM for 2 billion Korean won will allow the company to directly enter the Samsung supply chain [6] Group 4 - Anker Innovations is researching matters related to issuing shares overseas [7] - Shantui Co., Ltd. plans to issue H-shares and apply for listing on the main board of the Hong Kong Stock Exchange [7] - ASML, a Dutch lithography machine giant, stated that U.S. tariff policies have created uncertainty regarding the company's growth prospects [8]

Group 1 - The relationship between President Trump and entrepreneur Elon Musk has deteriorated, with Trump warning Musk of severe consequences if he supports the Democratic Party in future elections [1][5][6] - The White House has reportedly asked Republican supporters to choose sides between Trump and Musk, indicating a push to isolate Musk from Republican allies [2][3] - Trump has threatened to cancel government contracts and subsidies for Musk's companies, such as SpaceX and Tesla, which could save the government significant funds [7] Group 2 - Musk has publicly criticized the Republican Party's tax and spending proposals, which has raised concerns among Republicans about the potential impact on their legislative agenda [7][10] - Despite the ongoing conflict, some Republicans are advocating for reconciliation between Trump and Musk, citing Musk's previous contributions to the Republican Party and his influence on young voters [11][12] - Political analysts suggest that the Republican Party needs to navigate the internal divisions carefully to maintain their majority in Congress, especially in competitive districts [12]

欢迎扫描下方二维码关注： 供稿：国家税务总局广东省税务局国际税收管理处 不具有独立法人地位或者按照税 收 协 定 规 定 不 认 定 为 对 方 国 家 (地区)的税收居民),其取得 的各项境外所得,无论是否汇回 中国境内,均应计入该企业所属 纳税年度的境外应纳税所得额。 所得来源地确定 销售货物所得 BIG 按照交易活动发生地确定 提供劳务所得 les 按照劳务发生地确定 转让财产所得 不动产转让按照不动产所在地确定 动产转让按照转让动产的企业或者 机构、场所所在地确定 权益性投资资产转让所得按照被投 资企业所在地确定 股息、红利等权益性投资所得 > 按照分配所得的企业所在地确定 利息、租金、特许权使用费所得 按照负担、支付所得的企业或者机 构、场所所在地确定 其他所得 由国务院财政、税务主管部门确定 所得实现年度确定 企业来源于境外的股息、红利等 权益性投资收益所得 若实际收到所得的日期与境外被投资方作出 利润分配决定的日期不在同一纳税年度的, 应按被投资方作出利润分配日所 在的纳税年度确认境外所得。 企业来源于境外的利息、租金、 特许权使用费、转让财产等收入 若未能在合同约定的付款日期当年收到上述 所得 ...