↓上下更多↓ 注意： 新政策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。 ↓上下更多↓ | 条件 | 具体规定 | | --- | --- | | 利润来源 | 境外投资者分得的利润属于中国境内居民企业向投资者实际分 | | | 配的留存收益而形成的股息、红利等权益性投资收益。 | | | 境外投资者以分得利润进行的境内直接投资，包括境外投资者 以分得利润进行的增资、新建、股权收购等权益性投资,但 | | 投资方式 | 不包括新增、转增、收购上市公司股份（符合条件的战略投资 | | | 除外）。 | | | 在境外投资者境内再投资期限内,被投资企业从事的产业属于 | | 被投资企业 | 《鼓励外商投资产业目录》所列的全国鼓励外商投资产业目 | | | 录。 | | 投资期限 | 境外投资者境内再投资需连续持有至少5年（60个月）以上。 | | 支付方式 | 境外投资者用于境内直接投资的利润以现金形式支付的,相关 | | | 款项从利润分配企业的账户直接转入被投资企业或股权转让方 | | | 账 ...

欢迎扫描下方二维码关注： 企业所得税政策(即递延纳税政策) 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。 15243 = 1.77 上面提到的递延纳税政策为: 对境外投资者从中国境内居民企业分配的利 润,直接投资于所有非禁止外商投资的项目和 领域,凡符合规定条件的,实行递延纳税政 策,暂不征收预提所得税。 如选择适用10%的比例,则该再投资税收抵 免额度为100万元,2031年10月,B公司收回 10% 投资并申报补缴递延的税款时,应就该再投 资缴纳税款100万元,不得适用税收协定5% 的征税比例。 如选择适用5%,则该再投资税收抵免额度为 50万元,在收回投资时,应按照此前已确认 的税收协定5%的比例计算缴纳税款50万元; 5% 如后续税务机关认定B公司不符合享受税收 协定待遇条件,并要求就该再投资对应利润 缴纳100万元税款,纳税人可按补缴的税款 相应调增其税收抵免额度。 a 浙江 税务 02 境外投资者再投资时,如何计算税收 抵免额度? 境外投资者再投资时, ...

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]

Core Points - The announcement outlines a tax credit policy for foreign investors reinvesting profits, allowing them to defer corporate income tax while enjoying a temporary tax incentive [1][23][26] - The policy is effective from January 1, 2025, and will remain in place until December 31, 2028, with provisions for any remaining credits to be utilized thereafter [20][26] Group 1: Tax Credit Policy Overview - The tax credit policy provides a temporary tax incentive for foreign investors reinvesting profits, allowing them to defer corporate income tax [1][23] - Foreign investors can choose to calculate the tax credit based on either 10% of the reinvestment amount or a lower dividend withholding tax rate as per applicable tax treaties [3][24] - The policy does not affect the existing deferred tax policies, which remain applicable [1][2] Group 2: Reinvestment Timeframe - The reinvestment period for foreign investors begins from the month specified in the "Profit Reinvestment Situation Table" issued by the business authority [2][23] - The holding period for the reinvestment must be at least five years (60 months) to qualify for the tax credit [2][6] Group 3: Calculation of Tax Credit Amount - The tax credit amount can be calculated based on the reinvestment amount, with options to select a 10% rate or a lower rate from tax treaties [3][24] - If a foreign investor has multiple reinvestments, the tax credit must be aggregated by the profit distribution enterprise [3][24] Group 4: Adjustments and Compliance - If a foreign investor does not meet the conditions for the tax credit, adjustments to the tax credit amount will be required [6][26] - Foreign investors must submit specific documentation to the tax authorities when claiming the tax credit or making tax payments [25][26] Group 5: Handling of Tax Credits Post-2028 - Any remaining tax credit balances after December 31, 2028, can still be utilized until fully exhausted [20][26] - Foreign investors can apply for retroactive tax credits for eligible investments made between January 1, 2025, and the announcement date [21][26]

Core Viewpoint - The announcement by the National Taxation Administration regarding the tax credit policy for foreign investors reinvesting distributed profits provides clarity on the implementation of tax deferral and tax credit policies, ensuring that foreign investors can benefit from these incentives while adhering to specific conditions [1][2]. Group 1: Tax Deferral Policy - The tax deferral policy remains effective despite the issuance of the new announcements, allowing foreign investors to continue enjoying the benefits of deferring corporate income tax on reinvested profits [1]. - Foreign investors can still benefit from the tax credit policy while enjoying the tax deferral policy [1]. Group 2: Reinvestment Timeframe - The reinvestment period for foreign investors is calculated based on the month specified in the "Profit Reinvestment Situation Table" issued by the business authority, with the earlier of the month of investment recovery or the completion of legal changes marking the end of the reinvestment period [2]. Group 3: Tax Credit Calculation - The tax credit amount for reinvestment is determined based on two scenarios: either 10% of the reinvestment amount or a lower dividend tax rate as per applicable tax treaties, with the chosen rate being fixed for future calculations [3]. - For multiple reinvestments by the same foreign investor, the tax credit amounts must be aggregated separately for each profit distribution enterprise [3]. Group 4: Adjustments to Tax Credit Amounts - If a foreign investor does not meet the conditions for the tax credit policy, adjustments to the tax credit amounts will be required [6]. - In cases where a foreign investor recovers part of their investment before the five-year holding period, the tax credit amount must be reduced accordingly [7]. Group 5: Late Payment Penalties - Foreign investors who incorrectly benefit from the tax credit policy and underpay taxes will incur late payment penalties starting from the date they enjoyed the tax credit [8]. Group 6: Eligible Tax Amounts for Credit - The eligible tax amounts for credit must meet specific criteria, including being derived from the same profit distribution enterprise and occurring after the reinvestment period [9]. Group 7: Currency Conversion for Reinvestment - When foreign investors reinvest in currencies other than RMB, the reinvestment amount must be converted to RMB using the middle exchange rate on the actual payment date [10]. Group 8: Tax Payment Procedures upon Investment Recovery - Upon recovering investments that enjoyed the tax credit policy, foreign investors must differentiate between those that meet the tax credit conditions and those that do not, calculating the tax and penalties accordingly [11]. Group 9: Order of Investment Recovery - The order of recovering investments is prioritized based on whether they have enjoyed the tax credit policy, with specific sequences for different types of investments [13]. Group 10: Handling Remaining Tax Credit Balances - Foreign investors with remaining tax credit balances after December 31, 2028, can continue to utilize these credits until the balance is exhausted [20]. Group 11: Retroactive Application of Tax Credit Policy - Foreign investors can apply for retroactive tax credits for eligible investments made between January 1, 2025, and the announcement date, but these credits can only offset taxes incurred after the announcement [21].

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]