欢迎扫描下方二维码关注： 财政部、税务总局、商务部联合发布了 《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》 (财政部 税务总局 商 务部公告2025年第2号），国家税务总局随后出台了 《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》 （国家税务总局公告2025年第18号）。为帮助广大境外投资者清晰、准确掌握政策要点，今天我们为大家全面梳理、 通俗解读。 与递延纳税政策的关系 基本规定 一 再投资抵免政策 是在递延纳税政策基础上，对境外投资者在2025至2028年期间以境内分配利润新增的 有效投资给予阶段性税收 优惠 。再投资抵免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。境外投资者享受税收抵免政策的，仍可享受递 延纳税政策。 境外投资者以中国境内居民企业分配的利润，在 2025年1月1日至2028年12月31日 期间用于境内直接投资符合条件的，可按照 投 资额的10% 抵免境外投资者当年的应纳税额，当年不足抵免的准予向以后结转。 中华人民共和国政府同外国政府订立的税收协定中关于股息、红利等权益性投资收益适用税率 低于10% 的，按照 协定税率 执 行。 境 ...

中新网山东新闻1月26日电(周艺伟 赵晓)人才是科技创新的首要资源，股权激励则是科技企业引才留 智、驱动创新的重要举措。今年山东省两会期间，山东省政协委员，济南中瑞税务师事务所所长、山东 省注册税务师协会副会长陈巧慧表示，当前，部分非上市公司在通过"有限合伙企业持股平台"实施股权 激励时，因递延纳税政策适用口径不一，正面临"政策看得见、实惠难落地"的困境。 陈巧慧深耕涉税服务一线20余年，她发现，有的税务机关认为，设立持股平台是出于管理便利和保障创 始人控制权的法律架构安排，经济实质仍是股权激励，应当允许递延纳税；有的税务机关则认定员工取 得的是合伙企业财产份额，而非公司股权，难以直接适用递延纳税政策，往往要求员工在取得股权时 按"工资、薪金所得"计算缴纳个人所得税。 在陈巧慧看来，这一政策执行的模糊地带，不仅导致员工在尚未获得股权激励现金流入时面临缴税压 力，使激励效果大打折扣，也迫使不少企业为规避风险放弃更优的持股平台架构，甚至搁置激励计划。 长此以往，可能影响山东省对优质科技企业和高端人才的吸引力，进而削弱整体创新生态的竞争力。 陈巧慧建议，由山东省税务局、财政厅等部门牵头，系统梳理该省科技企业在股权激 ...

Group 1 - The article emphasizes the benefits of personal pension plans, highlighting multiple incentives for new contributions in the new year [2][10] - It mentions a tax-deferred policy for personal pensions, allowing individuals to contribute up to 12,000 yuan annually [4] - The potential tax savings from contributions can reach up to 5,400 yuan, depending on the individual's taxable income [3][5] Group 2 - The article outlines various rewards for personal pension contributions, including a maximum of 88 yuan for first-time deposits and up to 380 yuan for annual contributions reaching 10,000 yuan [7][8] - Additional rewards are available for referring friends, with potential earnings of up to 2,000 yuan for successful referrals [8] - The article encourages individuals to start their pension plans now to secure a more stable financial future [10]

Core Viewpoint - The rapid implementation of foreign tax policies in Zhenjiang is enhancing investment confidence among foreign enterprises, as evidenced by the efficient services provided by local tax authorities [1][2][3]. Group 1: Efficient Tax Services - The "Zhengqi Tax" direct connection platform allows companies to submit tax-related requests quickly, receiving prompt responses from tax authorities, which significantly eases the process for businesses [2]. - Zhenjiang's tax department has established a dedicated service team to assist companies with complex tax forms, ensuring accurate completion and timely processing of requests [2][3]. Group 2: Support for Reinvestment - Foreign companies, such as Jiangsu Danfoss Power Systems, are increasingly willing to reinvest profits back into local operations, facilitated by favorable tax policies and proactive support from tax authorities [3][4]. - The tax department's involvement in the entire process of project planning and execution has been crucial for companies relocating operations to Zhenjiang, ensuring smooth transitions and capacity expansions [3]. Group 3: Compliance and Risk Management - The "Tax Health Check" initiative by the tax department provides companies with a comprehensive assessment of their tax compliance, helping to identify and mitigate risks before they escalate [5][6]. - This proactive approach to tax management reflects a shift from reactive oversight to preventive measures, aligning with the needs of foreign enterprises in a complex economic environment [6].

Core Viewpoint - The article discusses the implementation of tax credit policies for foreign investors reinvesting distributed profits in China, emphasizing the deferred tax policy and the calculation of tax credit amounts based on specific conditions [2][4]. Group 1: Deferred Tax Policy - The deferred tax policy for foreign investors remains effective, allowing them to reinvest profits distributed from Chinese resident enterprises without incurring withholding income tax [2]. - Foreign investors can choose to calculate the tax credit amount based on either 10% of the reinvestment amount or a lower dividend tax rate specified in applicable tax treaties [2][4]. Group 2: Tax Credit Calculation - In the first scenario, if a foreign investor meets the conditions, they can select between a 10% or a lower tax treaty rate for calculating the tax credit [4]. - In the second scenario, if a foreign investor has multiple eligible reinvestments, the tax credit amounts must be aggregated separately for each profit-distributing enterprise [5]. Group 3: Currency Conversion - When reinvesting in currencies other than RMB, the reinvestment amount should be converted to RMB using the middle exchange rate on the actual payment date to calculate the deferred tax and tax credit [10]. Group 4: Adjusting Tax Credit Amounts - Tax authorities may adjust the tax credit amount if they determine that a foreign investor does not qualify for the tax credit policy, such as if the investment is withdrawn before five years [11]. Group 5: Tax Payment Procedures - Foreign investors must differentiate whether they meet the tax credit policy conditions when recovering investments and calculate the tax and penalties accordingly [12][16]. Group 6: Investment Recovery Order - The order of recovering investments is established as follows: investments that have enjoyed tax credits first, followed by those that meet but have not enjoyed the policy, then those under deferred tax policy but not qualifying for tax credits, and finally other investments [16].

Core Points - The announcement by the Ministry of Finance, State Administration of Taxation, and Ministry of Commerce regarding the tax credit policy for foreign investors reinvesting distributed profits remains effective, allowing for deferred tax payment on eligible reinvestments [2][3]. Group 1: Tax Credit Policy - The deferred tax policy allows foreign investors to reinvest profits distributed from Chinese resident enterprises into non-restricted foreign investment projects without incurring withholding income tax [2]. - When calculating the tax credit amount for reinvestment, foreign investors can choose between a 10% rate or a lower rate specified in applicable tax treaties [3][5]. - An example illustrates that if a foreign company receives a profit of 10 million yuan and reinvests it, it can choose to apply either a 10% or a 5% tax rate for calculating the tax credit [4][5]. Group 2: Tax Credit Adjustment - If a foreign investor does not meet the conditions for enjoying the tax credit policy, the tax credit amount must be adjusted accordingly [8]. - An example shows that if a foreign investor recovers part of their investment before five years, they must adjust their tax credit amount and pay the corresponding deferred tax [8][13]. - The order of recovering investments is specified, prioritizing those that have enjoyed the tax credit policy [15][22]. Group 3: Currency and Tax Reporting - For reinvestments made in currencies other than RMB, the amount must be converted to RMB using the exchange rate on the payment date to calculate the deferred tax and tax credit [7]. - Foreign investors must submit specific tax forms when recovering investments, detailing the tax credit and any taxes owed [9][14].

Core Viewpoint - The new tax credit policy for foreign investors allows them to enjoy a 10% tax credit on reinvested profits from January 1, 2025, to December 31, 2028, while maintaining the effectiveness of the deferred tax policy [8][17]. Summary by Relevant Sections Tax Credit Policy - Foreign investors can receive a tax credit of 10% on the amount of reinvested profits during the specified period, with any unused credit eligible for carryover to future years [8][17]. - The tax credit applies to profits distributed by Chinese resident enterprises, which are reinvested in eligible domestic investments [5][12]. Investment Conditions - The profits must be derived from equity investments such as dividends and retained earnings from Chinese resident enterprises [5]. - The reinvestment must be held for a minimum of 5 years (60 months) [6][12]. - The investment must be in industries listed in the "Encouraged Foreign Investment Industry Catalog" [5][12]. Application Process - Foreign investors must submit relevant information through the invested enterprise to the local commerce department for verification [19][20]. - Upon approval, the invested enterprise will provide a "Profit Reinvestment Situation Table" to the foreign investor [19][20]. Tax Credit Adjustment - If a foreign investor withdraws part of the reinvested capital before the 5-year holding period, the tax credit amount will be adjusted accordingly [9][12]. - For example, if a foreign investor reinvests 10 million yuan and later withdraws 7 million yuan, the tax credit will be reduced by 700,000 yuan [9]. Documentation Requirements - To claim the tax credit, foreign investors must submit several documents, including the "China Tax Withholding Report" and the "Foreign Investor Reinvestment Tax Credit Information Report" [21][22]. - The invested enterprise must also report the necessary information to the tax authorities [22].

Core Viewpoint - The article discusses the effectiveness of the deferred tax policy for corporate income tax and clarifies that the relevant documents continue to apply, ensuring that foreign investors can still enjoy the deferred tax policy when reinvesting [2][21]. Summary by Sections Deferred Tax Policy - The deferred tax policy allows foreign investors to postpone withholding income tax on profits distributed from Chinese resident enterprises when reinvested in non-restricted foreign investment projects [4][21]. Tax Credit Calculation for Reinvestment - When foreign investors reinvest, the tax credit amount is calculated based on two scenarios: 1. For compliant enterprises, the credit can be calculated at either 10% or a lower rate specified in applicable tax treaties [6][5]. 2. If multiple compliant domestic investments exist, the tax credit must be aggregated by each profit-distributing enterprise [9][8]. Currency Conversion for Reinvestment - If reinvestment is made in currencies other than RMB, the amount should be converted to RMB using the middle exchange rate on the actual payment date to calculate the deferred tax and tax credit [10][11]. Adjustment of Tax Credit Amount - Tax authorities may adjust the tax credit amount if it is found that the foreign investor does not qualify for the tax credit policy, such as when the reinvestment is held for less than five years [12][13]. Understanding "Tax Amount Eligible for Credit" - The tax amount eligible for credit must meet specific conditions, including the type of income and the timing of income acquisition relative to reinvestment [14][15]. Holding Period for Reinvestment - The holding period for reinvestment begins from the month indicated in the "Profit Reinvestment Situation Table" issued by the business authority and ends when the investment is recovered or legal changes are completed [16][17]. Tax Payment Procedures for Recovered Investments - When recovering investments that enjoyed the tax credit policy, foreign investors must distinguish whether they meet the conditions for the tax credit and calculate the tax and penalties accordingly [21][27]. Order of Investment Recovery - The order of recovering investments is determined by the type of investment, prioritizing those that have enjoyed the tax credit policy [30][31]. Tax Payment for Partial Disposal of Investments - If a foreign investor recovers investments before five years, they must pay deferred taxes and proportionally reduce the tax credit amount [36][35]. Handling of Remaining Tax Credit Balances - Tax credits that remain after December 31, 2028, can still be utilized until the balance is zero [48].

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]