Core Points - The announcement by the State Taxation Administration clarifies the implementation of the tax credit policy for foreign investors reinvesting distributed profits in China from January 1, 2025, to December 31, 2028, allowing a 10% tax credit on the investment amount [1][2] - The Ministry of Commerce reported that in the first half of 2025, there were 30,014 newly established foreign-invested enterprises, a year-on-year increase of 11.7%, while the actual use of foreign capital decreased by 15.2% to 423.23 billion yuan [1] Group 1: Tax Credit Policy - The tax credit policy allows foreign investors to offset their taxable income by 10% of the reinvested profits from January 1, 2025, to December 31, 2028, with the possibility of carrying forward any unused credits [1][2] - The policy does not affect the existing deferred tax policy, allowing foreign investors to benefit from both tax credit and deferred tax policies [2] Group 2: Reinvestment Guidelines - Foreign investors must confirm the reinvestment period based on the month indicated in the profit reinvestment report issued by the business authority [3] - The tax credit amount can be calculated based on either 10% of the reinvestment amount or the applicable lower tax rate from tax treaties, with the chosen method being fixed for future calculations [3][4] Group 3: Compliance and Adjustments - Tax authorities will adjust the tax credit amount if foreign investors do not meet the eligibility criteria, such as withdrawing investments before five years [4][5] - If foreign investors enjoy the tax credit but later find they do not qualify, they will need to pay back taxes along with late fees from the date they first benefited from the tax credit [5] Group 4: Currency and Tax Handling - For reinvestments made in currencies other than RMB, the amount must be converted to RMB at the exchange rate on the payment date for tax credit calculations [7] - When recovering investments that have benefited from the tax credit, foreign investors must differentiate between those that have and have not enjoyed the tax credit for tax payment calculations [9]

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].

Core Viewpoint - The personal pension system in China will be implemented nationwide starting December 15, 2024, after a two-year pilot in 36 cities, allowing all workers participating in basic pension insurance to join the scheme [1] Group 1: Implementation and Participation - The personal pension accounts can be opened through various online platforms and commercial banks, with a contribution limit of 12,000 yuan per year for purchasing approved financial products [1] - As of November 2024, 72.79 million personal pension accounts have been opened, although issues such as "high account opening but low contributions" need to be addressed [1] Group 2: Tax Policy and Economic Viability - The personal pension system adopts an EET (Exempt-Exempt-Tax) tax model, aiming to encourage middle and high-income groups to supplement their retirement savings while providing stable long-term capital for the market [2] - For ordinary participants, the economic benefits depend on the marginal tax rate and asset allocation efficiency, with those in higher tax brackets benefiting from tax deductions and investment returns [3] Group 3: Optimization and Improvement - Key issues include imbalanced tax incentives, low expected returns on pension financial products, and strict liquidity constraints, which hinder participation and investment confidence [4][5] - Recommendations for improvement include implementing tiered tax incentives, expanding the product range, and establishing flexible withdrawal rules for specific circumstances [5][6] Group 4: Young People's Investment Planning - Young individuals are encouraged to start planning for retirement investments, ideally between the ages of 35 and 40, focusing on long-term asset accumulation to ensure a smooth transition into retirement [6][7] - Emphasizing a disciplined investment approach, such as regular contributions, can help mitigate the impact of market volatility and achieve stable asset growth over time [7]