Core Insights - The concept of "going global" has shifted from an optional strategy to a critical necessity for companies due to increasing tariff barriers and changes in global trade dynamics [1] - A well-structured investment framework is essential for successful overseas expansion, impacting tax liabilities, risk management, and overall business sustainability [1] Group 1: Overseas Mergers and Acquisitions - Overseas mergers and acquisitions (M&A) are vital for companies to expand their market presence and acquire resources quickly [5] - Key factors in designing a cross-border M&A structure include the acquirer's financial strength, safety and convenience of entry and exit, cost savings, and compliance with local regulations [8] - Five critical considerations for M&A structure design include the type of acquisition (direct or indirect), the level of acquisition (single or multi-layer), the acquisition process (one-step or phased), payment methods (cash or shares), and the implications for transaction documents and risk allocation [8][9] Group 2: Tax Planning for Overseas Investment - Tax structure design is crucial for companies going global, directly affecting investment returns and risk exposure [10] - Common tax compliance risks for outbound investments include understanding the target country's tax system, investment structure (direct vs. indirect), financing arrangements, and personnel management [12][13] - Effective tax planning can reduce tax burdens and enhance investment flexibility, with considerations for permanent establishment risks and cross-border transactions [14] Group 3: Equity Structure for Overseas Investment - The design of equity structures for overseas investments is linked to tax, financing, legal compliance, and operational efficiency [16] - Key factors in equity structure design include the business environment of the host country, profit repatriation tax rates, and operational layout [16] - Examples of effective equity structures include setting up top-tier investment companies in tax-friendly jurisdictions to minimize tax liabilities and isolate risks [17]

Core Insights - Recent developments in tax collection regarding personal overseas income have gained significant attention, with various tax authorities in regions like Shanghai, Zhejiang, Shandong, and Hubei intensifying their scrutiny and enforcement actions [2][3] Group 1: Tax Collection Measures - Tax authorities are implementing a systematic inspection process driven by big data, utilizing a "Five-Step Work Method" to enhance risk management and compliance [3] - The approach includes steps such as reminders, corrective actions, interviews, investigations, and public exposure to ensure thorough oversight of overseas income reporting [3] - Tax authorities are leveraging big data to identify potential non-compliance by analyzing cross-border financial flows and taxpayer records [3][4] Group 2: Information Transparency - The implementation of the Common Reporting Standard (CRS) has facilitated the exchange of overseas financial account information, enhancing transparency for Chinese tax residents [4] - This exchange includes details on bank deposits, securities investments, and income from various financial assets, which are now accessible to domestic tax authorities [4] - Upgraded data inspection technologies are improving the efficiency of tax collection on overseas income by integrating various data sources [4] Group 3: Focus on Overseas Investment Income - As more Chinese residents engage in overseas investments, capital gains and income from these investments have become a focal point for personal income tax collection [5] - Tax authorities are conducting targeted audits on high-income individuals who may have significant unreported overseas income from stock trading and other investments [5] Group 4: Challenges in Tax Residency Determination - The complexity of determining tax residency status arises from the diverse living and working conditions of individuals, especially those with significant cross-border activities [6] - Disputes may occur regarding the application of tax treaties and the understanding of tax exemptions for income earned abroad [7] Group 5: Anti-Avoidance Measures - The application of anti-avoidance provisions allows tax authorities to adjust tax liabilities for unreasonable business arrangements, but the lack of clear standards complicates enforcement [9] - The need for professional tax advisory services is emphasized to navigate the complexities of overseas income tax compliance and to mitigate potential disputes with tax authorities [9][10]

欧洲凭借其强大的经济实力和市场稳定性，长期吸引着全球企业和投资者的目光，但其独特的治理模式和法规环境也使得市场进入面临一定的门槛。 安永在中国与亚太地区的欧洲税务团队将合作举办研讨会，探讨欧洲不断演变的投资环境和动态税务格局，安永诚邀您的参与。本次会议面向正在探索欧 洲新业务拓展机会，或寻求优化现有欧洲业务的中国企业。 2. Ernst & Young Tax Co 3. EY Corporate Advisors Pte. Ltd 4. EY & Associés 5. EY Belastingadviseurs B.V. 6. EY LLP 本文是为提供一般信息的用途所撰写，并非旨在成为可依赖的会计、税务、法律或其他专业意见。请向您的顾问获取具体意见。 会议将聚焦中国在欧洲的三大主要贸易伙伴国——德国、荷兰和英国，深入探讨其基本税收原则及最新税收动态。此外，还将举行专题讨论，由安永中国 海外投资业务部的资深税务专业人士分享他们在支持中国企业投资欧洲市场方面的宝贵经验和见解。本次会议旨在为参会者提供拓展欧洲业务所需的基本 知识，助力参会者把握欧洲市场拓展机遇，做出明智且具战略意义的投资决策。 ► 欧洲经济发 ...

基础设施行业企业在海外投资的税务风险有哪些？ 基础设施行业企业在海外投资的业务模式种类有哪些？ 基础设施行业企业在海外投资的税收优化方案有哪些？ 在国内竞争日益激烈的背景下，基础设施行业企业为寻求新的机遇与增长点进行国际化已成为必然趋势。然而，复杂的国际税务环境、合规要求及投资风 险，成为企业"走出去"的关键挑战。为此，安永[1]致力于助力基础设施行业企业国际化税务服务，提供端到端税务解决方案，为中国内地企业提供从战略 规划到落地运营的全周期税务服务支持，助力企业高效应对海外投资难题。 安永[1]提出，基础设施行业企业在海外投资中普遍面临五大核心问题： 1. 市场准入与政策适配 不同国家的市场准入政策、外资限制、行业监管差异大，企业难以快速掌握目标国的投资环境。因此如何选择目标市场、匹配最优业务模式（如EPC、 PPP等）并落实税收优惠成为首要问题。 安永方案： 2. 现金流与税负管理 出海企业的另一大难题是跨境资金流动受限，利润汇回税负高，集团整体税负难以优化。因此跨境资金流动、利润汇回及全球税负优化也是企业关注的重 点。 安永方案： 3. 合规风险 随着国际税收监管趋严（如BEPS行动计划、国别报告），企 ...