研讨会吸引了众多生命科学行业企业代表及投资机构人士线上参与，嘉宾与参会者围绕实务问题展开积 极互动，交流气氛热烈，获得与会各方一致好评。 安永[1]生命科学与医疗健康行业亚太及大中华区税务主管合伙人苏学敏(Joanne Su)开场分享近年来对生 命科学行业出海的观察。 苏学敏(Joanne Su) 安永[1]生命科学与医疗健康行业亚太及大中华区税务主管合伙人 近期Biotech企业在BD领域呈现了大型交易，展现出国内Biotech领域快速发展的势态，国内Biotech企业 在推动全球创新方面正发挥着越来越关键的作用。Biotech企业通过对外授权许可(license-out)、设立海 外运营实体或合资企业(New Co)等方式拓展全球市场，涉及跨境IP安排、研发活动布局与利润分配、转 让定价和经济实质等复杂的税务议题，尤其在全球税收规则重塑的背景下，OECD主导的支柱二GloBE 不仅影响企业跨境利润分配，更直接关联其全球投资与运营的战略决策。 安永[1]国际及并购重组税务服务转让定价合伙人邓婷分享了当前中国生命科学企业就BD的税收规划机 会。 当下中国生命科学产业创新力量正崭露头角，出海浪潮奔涌；生物技术( ...

Core Insights - Central Asian countries are actively promoting economic diversification strategies, resulting in distinct industrial structures, with Chinese enterprises focusing on investments in energy, infrastructure, agricultural processing, manufacturing, and services [1] Tax Environment Overview - The tax environment for Chinese enterprises in Central Asian countries is complex, with variations in tax types, rates, and incentives across nations [2] - Kazakhstan has a VAT rate of 12%, with certain exports and international transport services exempted; Uzbekistan also has a 12% VAT rate with specific exemptions [2] - Corporate income tax rates vary, with Kazakhstan at 20%, Uzbekistan at 15%, and Kyrgyzstan at 10% for certain sectors [2] Common Tax Risks - Tax reforms and lack of clarity create uncertainty; Kazakhstan's new tax law will take effect on January 1, 2026, and transfer pricing rules will also be updated [3] - There is a risk of differing interpretations of tax laws by tax authorities, leading to uncertainty in enforcement [3][4] Permanent Establishment Risks - Chinese enterprises involved in infrastructure and engineering projects face scrutiny regarding whether they create a permanent establishment in the host country, which could lead to local tax obligations [5] - In Kazakhstan, local entities are considered tax agents responsible for withholding taxes on payments to unregistered foreign suppliers [5] Utilizing Tax Treaties - China has signed tax treaties with Central Asian countries, allowing for reduced withholding tax rates on dividends, interest, and royalties under certain conditions [6] - Kazakhstan has strict scrutiny for treaty benefits, particularly regarding the "beneficial owner" concept, while Uzbekistan has recently introduced this concept [6] Transfer Pricing Risks - Transfer pricing practices vary significantly across Central Asian countries, with Kazakhstan and Uzbekistan having more developed frameworks compared to others [7] - Kazakhstan has stringent compliance checks, especially for transactions in the oil, gas, and mining sectors [7] Customs Duties and Tax Recommendations - Customs duties differ significantly among Central Asian countries, with Kazakhstan's average most-favored-nation tariff rate at 5.6% for 2024 [9] - Companies are advised to assess compliance costs and utilize tax incentives effectively when planning cross-border transactions [9]