Workflow
非居民税收抵免政策
icon
Search documents
非居民税收online看 | @境外投资者,分配利润直接投资税收抵免政策热点问答(二)
蓝色柳林财税室· 2025-10-11 13:45
Core Viewpoint - The article discusses the tax credit policy for foreign investors reinvesting in domestic companies, detailing the conditions and calculations for tax credits and liabilities associated with dividend distributions and reinvestments [4][8][10]. Group 1: Tax Credit Eligibility - Foreign investors can claim tax credits on corporate income tax if they meet specific conditions, including receiving income from the same profit-distributing enterprise and the income type being dividends, interest, or royalties [4]. - The timing of income acquisition must be after the reinvestment date to qualify for tax credits [4]. Group 2: Tax Credit Calculation - 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 to calculate deferred dividend income tax and tax credit amounts [6]. - For example, if a foreign investor receives a profit distribution of 1,000 million USD and reinvests it, the tax credit amount can be calculated based on the exchange rate on the reinvestment date [7]. Group 3: Tax Payment and Reporting - When foreign investors withdraw investments that have enjoyed tax credits, they must differentiate whether the withdrawal meets the tax credit policy conditions and calculate the tax and penalties accordingly [8]. - The order of investment recovery should follow a specific sequence: investments that have enjoyed tax credits first, followed by those that have not but meet the conditions, and finally those that do not meet the tax credit policy [10]. Group 4: Handling Remaining Tax Credits - The tax credit policy is effective from January 1, 2025, to December 31, 2028, and any remaining tax credits after this period can still be utilized until the balance is zero [10].