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SAT Issues Guidance on Tax Administration of Enterprise Reorganizations

Tax Analysis:July 17, 2015/China

New guidance issued by China’s State Administration of Taxation (SAT) on 24 June 2015 ("Issues Relating to the Collection and Administration of Enterprise Income Tax (EIT) on Enterprise Reorganizations (Bulletin [2015] No. 48, "Bulletin 48")) is designed to promote mergers and acquisitions and reorganizations between enterprises, and to clarify certain issues arising from current practices. (Tax Analysis:July 17, 2015/China)

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Bulletin 48 makes major changes to guidance issued in 2010 ("Administrative Measures on the EIT Treatment of Enterprise Reorganizations" (Bulletin [2010] No. 4, "Bulletin 4")); although Bulletin 4 remains in effect, a number of its procedural guidelines are repealed or amended. Bulletin 48 applies to enterprise reorganizations completed in 2015 and subsequent years. Bulletin 48 also applies to reorganizations for which the agreements have been signed, but the transactions have not yet been completed.

This newsletter explains following topics;

(1) Background
(2) Highlights of Bulletin 48

>> Click for Japanese [中国国家税務総局が企業再編に係る企業所得税の管理に関する指針を公布]

(175KB, PDF)

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