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Tuesday, October 12, 2010

Implications of China’s foreign tax credit regime on outbound investment structures World Tax Advisor

World Tax Advisor


Implications of China’s foreign tax credit regime on outbound investment structures



China’s State Administration of Taxation (SAT) issued long-awaited guidance on 22 July 2010 (Bulletin No. 1 “Guidance on Administration of PRC Enterprise Foreign Tax Credit,” or “Guidance”) that provides a detailed interpretation and examples of the calculation of the foreign tax credit (FTC) available under articles 23 and 24 of the Enterprise Income Tax Law (EIT Law) and its implementation rules. The Guidance is intended to supplement Circular No. 125, a notice issued jointly by the SAT and the Ministry of Finance at the end of 2009.
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