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]

Group 1 - Europe attracts global businesses and investors due to its strong economic power and market stability, but its unique governance model and regulatory environment create entry barriers [2] - Ernst & Young (EY) is organizing a seminar in collaboration with its European tax team to discuss the evolving investment environment and dynamic tax landscape in Europe [2] - The seminar targets Chinese companies exploring new business opportunities in Europe or seeking to optimize existing operations [2] Group 2 - The seminar will focus on three major trading partner countries of China in Europe: Germany, the Netherlands, and the United Kingdom, covering their basic tax principles and recent tax developments [2] - Key topics include financing, profit repatriation, and tax incentives within the tax systems of Germany, the Netherlands, and the UK [2] - A discussion session will feature experienced tax professionals from EY sharing insights on supporting Chinese enterprises in investing in the European market [2]

Core Insights - The infrastructure industry is increasingly pursuing internationalization to seek new opportunities and growth amid intense domestic competition, facing challenges such as complex international tax environments and compliance requirements [2][3] Group 1: Key Challenges in Overseas Investment - Market access and policy adaptation are critical, as different countries have varying market entry policies, foreign investment restrictions, and industry regulations, making it difficult for companies to quickly understand the investment environment [5] - Cash flow and tax burden management pose significant challenges, with cross-border capital flow restrictions and high profit repatriation taxes complicating overall tax optimization [6] - Compliance risks are heightened due to stricter international tax regulations, leading to increased compliance costs for companies [7] - Employee dispatch issues arise from the complexity of individual income tax, social security, and cross-border compensation arrangements, which can lead to tax disputes [8] - Dispute management is essential, as transfer pricing investigations and tax audits are frequent, and companies often lack the expertise to respond effectively [9] Group 2: EY's Solutions for Infrastructure Companies - EY provides country-specific investment guides covering policies, tax systems, and industry restrictions to assist companies in navigating foreign markets [11] - The firm helps design compliant entry models, such as joint ventures or PPPs, and identifies overseas employment risks while offering optimization suggestions [11] - EY assists in applying for tax incentives and financial subsidies, designing global holding structures to reduce withholding taxes, and optimizing financing models, achieving a reported 18% reduction in overall tax burden in one case [11] - The firm offers real-time tracking of tax regulation changes in over 150 countries and provides regular updates and interpretations of foreign tax laws [11] - EY conducts tax health checks to identify risk points early and designs compensation policies to optimize dispatch costs while ensuring compliance with tax and social security requirements [11] - A global tax dispute management framework is established to unify response strategies and mitigate tax risks through advance pricing agreements (APAs) [11] Group 3: Specific Business Models and Services - International engineering contracting involves companies undertaking construction projects through various contractual arrangements, with EY providing tax optimization services for EPC contracts and compliance for cross-border labor [14] - Overseas project investment includes activities where entities invest assets to gain ownership and management rights, with EY focusing on investment planning and operational optimization [15] - Export business management for overseas projects includes guidance on export tax refunds, with EY enhancing efficiency by 50% in tax exemption processes [16] - Domestic tax credit strategies are implemented to allow companies to offset domestic tax liabilities with taxes paid abroad, promoting international expansion [17][18] - Information disclosure is crucial under BEPS action plans, with EY assisting in compliance with international tax regulations and transfer pricing documentation [19] Group 4: EY's Global Network and Services - EY leverages a global tax service network with over 300 professionals across 60 countries, providing rapid access to insights and research on investment opportunities, particularly in green infrastructure and digital engineering [20] - The firm offers real-time policy tracking, risk alert systems, and digital simulations to assist in decision-making regarding investment structures [21] - EY aims to create new value for clients, employees, and society while building trust in capital markets through comprehensive professional services [23]

南方财经法律研究院 李玉敏 北京报道 随着经济社会快速发展和新业态新技术不断涌现，税收征管面临新的挑战。 国家税务总局、财政部于2025年3月28日公开发布《中华人民共和国税收征收管理法（修订征求意见 稿）》（以下简称"《征求意见稿》"），向社会公开征求意见，截止时间至2025年4月27日。 现行税收征管法于1993年实施，2001年全面修订，2013年、2015年配合商事制度改革对个别条文进行了 修正。本次征求意见稿中修改幅度较大，新增16条、删除4条、修改69条。新增的一个重要内容是大数 据时代的税收征收和平台经济的监管等内容。 其中，涉及平台的明确规定，电子商务平台经营者、其他网络交易平台经营者应当按规定报送平台内经 营者、从业人员的身份信息和与纳税有关的信息，按规定办理平台内经营者、从业人员纳税申报等相关 涉税事宜。 《征求意见稿》第七十二条第三款还规定了比较严重的处罚条款，"未依照本法第二十九条第三款规定 办理平台内经营者、从业人员纳税申报的，由税务机关责令限期改正，逾期仍不改正的，对电子商务平 台经营者和其他网络交易平台经营者处平台内经营者、从业人员不缴或者少缴的税款50%以上3倍以下 的罚款"。 ...