人民财讯12月30日电，司法部、财政部、税务总局负责人就《中华人民共和国增值税法实施条例》答记 者问表示，《条例》对增值税法第3条所称"货物""服务""无形资产"和"不动产"作出细化规定：一是货 物包括有形动产、电力、热力、气体等；二是服务包括交通运输服务、邮政服务、电信服务、建筑服 务、金融服务，以及信息技术服务、文化体育服务、鉴证咨询服务等生产生活服务；三是无形资产是指 不具实物形态，但能带来经济利益的资产，包括技术、商标、著作权、商誉、自然资源使用权和其他无 形资产；四是不动产是指不能移动或者移动后会引起性质、形状改变的资产，包括建筑物、构筑物等。 财政部、税务总局将出台配套文件，进一步提出货物、服务、无形资产、不动产的具体范围，报国务院 批准后公布施行。 ...

中国税务快讯 第十二期 二零二五年十一月 APA签署效率提高，双边APA受跨国企业青睐 摘要： 根据《中国预约定价安排年度报告（2024）》（以下简称"APA 年度报告" ）， 2024年中国税务机关共签署APA 39 例，其中单边APA 12例，双边APA 27例。2005年至2024年，中国税务机关累计签署APA 335例，其中单边APA 165 例，双边APA 170例。中国累计签署的双边APA数量首次超过单边APA。这反映出中国税务机关不断加强国际税收合 作，稳步推进预约定价安排，积极为纳税人创造良好的税收营商环境。 背景 毕马威观察 近年来，随着国际税收透明度的不断提升，各国对跨国企业的税收征管力度不断增强，APA日益成为跨国企业寻求税收 确定性的重要方式。从中国APA发展的总体趋势看，呈现以下几个方面特点。 注3：即处于意向及申请阶段的APA案件。 © 2025 毕马威华振会计师事务所(特殊普通合伙) — 中国合伙制会计师事务所，毕马威企业咨询 (中国) 有限公司 — 中国有限责任公司，毕马威会计师事务所 — 澳门特别行政区合伙制事务所，及毕马威会计师事务 所 — 香港特别行政区合伙制事务所，均是 ...

Group 1 - The article discusses the classification and tax basis of fixed assets, production biological assets, and intangible assets, emphasizing their importance in corporate financial management [2][10][17] - Fixed assets are defined as non-monetary assets held for more than 12 months for production, service provision, leasing, or management [2] - The tax basis for purchased fixed assets includes purchase price, related taxes, and other expenditures necessary to prepare the asset for its intended use [3] Group 2 - The tax basis for self-constructed fixed assets is based on expenditures incurred before completion [3] - For fixed assets acquired through donation, investment, or non-monetary exchanges, the tax basis is determined by fair value and related taxes paid [4] - The minimum depreciation period for various fixed assets is specified, with buildings and structures set at 20 years, and machinery and equipment at 10 years [6] Group 3 - The article outlines the depreciation methods for fixed assets, stating that depreciation should start from the month following the asset's use and stop when the asset is no longer in use [7] - The expected net residual value of fixed assets must be reasonably determined and cannot be changed once established [7] - Production biological assets are also discussed, with similar tax basis and depreciation rules as fixed assets [10][14] Group 4 - Intangible assets are defined as non-physical long-term assets held for production, service provision, or management, including patents, trademarks, and goodwill [17] - The tax basis for purchased intangible assets includes purchase price and related taxes, while self-developed intangible assets are based on expenditures incurred after meeting capitalization conditions [18] - The minimum amortization period for intangible assets is set at 10 years, with specific rules for purchased goodwill [20]

Group 1 - The company has approved a share repurchase plan using its own funds and a special loan for stock repurchase, with a total amount between RMB 25 million and RMB 50 million, and a maximum repurchase price of RMB 14 per share, later adjusted to RMB 13.95 per share [1][3] - As of October 2025, the company has repurchased a total of 756,300 shares, accounting for 0.0164% of the total share capital, with a total expenditure of RMB 7,469,047 [3][4] Group 2 - The company’s subsidiary, Sichuan Changhong Hongwei Technology Co., Ltd., has been authorized to purchase 22 intangible assets from the related party Sichuan Qirui Ke Technology Co., Ltd. for a total amount of RMB 23,256,020 [7][8] - The board meeting approved an increase in the daily related transaction limit for 2025 to RMB 12 million for providing fuel, power, and communication services to three related parties [10][11] Group 3 - The company has provided guarantees for its wholly-owned subsidiary, Hong Kong Changhong, totaling RMB 52 million and USD 2 million for loans from various banks, with no counter-guarantees [15][16][20] - The total amount of guarantees provided by the company and its subsidiaries is RMB 1,469,243.77 million, which is 100.22% of the latest audited net assets [23][24]

Core Points - The board of directors of Sichuan Changhong Electric Co., Ltd. approved the purchase of intangible assets from an affiliated company, with a total amount of 23,256,020 yuan [1][2] - The board also approved an increase in the daily related party transaction limit for 2025 to 12 million yuan for providing fuel, power, and communication services to three affiliated companies [4][5] - The company has been actively repurchasing its shares, with a total of 756,300 shares repurchased by the end of October 2025, representing 0.0164% of the total share capital [10][11] - The company provided guarantees for its wholly-owned subsidiary, Hong Kong Changhong, totaling 52 million yuan and 2.8 million USD for loans from various banks [15][16][20] - The total amount of external guarantees provided by the company and its subsidiaries reached 1,469,243.77 million yuan, exceeding the company's audited net assets [24][25] Group 1: Board Meeting Resolutions - The board meeting was held on October 31, 2025, with all nine directors present, and the resolutions were passed unanimously [1][3] - The purchase of intangible assets was deemed necessary for the operational development of the subsidiary [1] - The related party transaction limit increase was approved to meet the company's operational needs [4] Group 2: Share Repurchase Progress - The company initiated a share repurchase program with a total budget between 25 million and 50 million yuan, with a maximum repurchase price adjusted to 13.95 yuan per share [8][9] - As of October 2025, the company repurchased shares at prices ranging from 9.69 to 9.97 yuan per share [10] Group 3: External Guarantees - The company provided guarantees for loans to its subsidiary, with a total guarantee amount of 52 million yuan and 2.8 million USD [15][20] - The total external guarantee amount reached 1,469,243.77 million yuan, which is 100.22% of the company's latest audited net assets [24]

Core Points - The company has established a detailed asset acquisition and disposal procedure to ensure asset security and information transparency, in compliance with related regulations from ASE Technology Holding Co., Ltd [1][6] Asset Scope and Investment Limits - The asset scope includes various categories such as securities, real estate, membership certificates, intangible assets, usage rights, financial institution debts, and derivatives [2] - The total investment in non-operating real estate and usage rights cannot exceed 20% of the latest financial statement net value; total securities investment is limited to 200% of net assets, with individual securities capped at 120% of net assets [2] Transaction Procedures - Transactions involving securities require internal approval based on the amount; for amounts below 300 million, the chairman can approve, while amounts above require board resolution [3] - Real estate and equipment transactions follow internal control procedures, with specific approval limits for the chairman and requirements for capital expenditure plans and price references [3] - Intangible assets and membership certificates also follow internal control, with similar approval processes and requirements for price assessments [3] Related Party Transactions and Derivatives - Related party transactions require adherence to standard procedures, with evaluations needed for significant amounts; cost assessments must be verified by accountants [4] - Derivative transactions are permitted under specific conditions and require board approval, with clear distinctions between hedging and non-hedging strategies [4] Corporate Mergers and Acquisitions - Mergers, splits, acquisitions, or share transfers must involve professional consultation and documentation for shareholders, with strict principles governing changes in exchange ratios or acquisition prices [5] Information Disclosure and Subsidiary Control - Asset acquisition or disposal must be reported within two days to ASE Technology Holding Co., Ltd, with clear calculation methods for transaction amounts [6] - Subsidiaries are required to report to the board and shareholders, summarizing transaction situations monthly, which will be included in the annual audit plan by the parent company's auditing unit [6]

Core Viewpoint - The article discusses the treatment of intangible assets in corporate income tax, including their definition, tax basis, and amortization methods according to Chinese tax law [1][3][4]. Summary by Sections Definition of Intangible Assets - Intangible assets are defined as non-monetary long-term assets held by enterprises for production, service provision, leasing, or management, including patents, trademarks, copyrights, land use rights, non-patent technology, and goodwill [1]. Tax Basis for Intangible Assets - The tax basis for intangible assets is determined by historical cost, which refers to the actual expenditure incurred when acquiring the asset. Changes in asset value during the holding period do not adjust the tax basis unless specified by the relevant authorities [2]. Amortization of Intangible Assets - Intangible assets can be amortized for tax purposes, with the amortization calculated using the straight-line method. The minimum amortization period for intangible assets is set at 10 years [3]. Special Case of Goodwill - For purchased goodwill, the expenditure is deductible only during the overall transfer or liquidation of the enterprise. Intangible assets acquired as investments can be amortized based on the specified useful life in relevant laws or contracts [4]. Non-Deductible Intangible Assets - Certain intangible assets are not eligible for amortization deductions as specified in the tax law [5]. R&D Expense Deductions - When calculating R&D expense deductions, amortization costs for intangible assets used in R&D activities, such as software and patents, are included. If an intangible asset is used for both R&D and non-R&D activities, the company must allocate the amortization costs based on actual usage [7].

Core Viewpoint - The article discusses the classification, valuation, and amortization of intangible assets, emphasizing their significance in corporate financial management and tax implications. Group 1: Definition and Classification of Intangible Assets - Intangible assets are defined as non-monetary long-term assets without physical form, including patents, trademarks, copyrights, land use rights, non-patented technology, and goodwill [1]. Group 2: Tax Basis Confirmation - The tax basis for various assets, including intangible assets, is determined based on historical cost, which refers to the actual expenditure incurred when acquiring the asset [2][3]. - The tax basis for purchased intangible assets includes the purchase price, related taxes, and other direct expenditures necessary to make the asset ready for use [4]. Group 3: Amortization and Deduction of Intangible Assets - Amortization of intangible assets is calculated using the straight-line method and is allowed as a tax deduction [6]. - The minimum amortization period for intangible assets is set at 10 years, unless specified otherwise by legal regulations or contractual agreements [7]. - Expenditures related to purchased goodwill are deductible during the overall transfer or liquidation of the enterprise [8]. Group 4: Non-Deductible Amortization Expenses - Certain intangible assets are not eligible for amortization expense deductions, including: - Intangible assets for which development expenditures have already been deducted in taxable income calculations [9] - Self-created goodwill [9] - Intangible assets unrelated to business activities [9] - The article cites the "Corporate Income Tax Law of the People's Republic of China" and its implementation regulations as the policy basis for these provisions [9].

Core Viewpoint - Shenghong Technology (300476) plans to invest up to RMB 3 billion in fixed and intangible asset purchases for the year 2025, which includes new factory construction, equipment procurement, and automation line upgrades [1] Investment Plan - The investment scope encompasses new factory and engineering construction, equipment acquisition, and upgrades to automated production lines [1] - As of the announcement date, the company and its subsidiaries have already invested a total of RMB 252 million [1] Strategic Implications - The implementation of this investment plan is expected to enhance the company's core competitiveness and provide a guarantee for sustainable development [1]