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Multinational groups conducting cross-border related-party transactions must ensure their intercompany arrangements comply with the arm’s length principle. Transfer pricing rules apply to sales and purchase of goods, provision of services, licensing of intangible assets, and al…
Multinational groups frequently restructure their global presence, discontinuing certain businesses and winding down investment projects. While China remains a key market for many businesses, there is growing trend of restructuring and exits among foreign entities seeking to o…
Pursuant to the “Circular on Issues Concerning Treatment of Corporate Income Tax in Enterprise Restructuring Business” (Cai Shui [2009] No. 59, hereinafter “Circular 59”), the corporate income tax treatment for equity transfers can be categorized into two approache…
When a parent company receives dividends from a subsidiary, the accounting and tax treatment often don’t match. This is especially relevant for groups where an overseas parent — such as an Italian shareholder — holds a subsidiary in China. Here is a plain language breakdow…
In July 2026, the State Taxation Administration issued Announcement No. 13 of 2026, introducing new rules for the application of special tax treatment to enterprise mergers and divisions. The new rules apply to restructurings with an effective date on or after 1 January …
In 2026, China’s export tax enforcement landscape has undergone a fundamental shift. Regulatory focus has moved beyond merely cracking down on tax refund fraud to demanding answers to a deeper question: “What is the true commercial logic behind this export?” Driven by big da…
Reports have recently circulated online that Pan Shiyi and Zhang Xin of SOHO China face a huge back-tax bill on equity they placed into an offshore trust two decades ago; that Haidilao founders Zhang Yong and his wife are exposed through their own trust structure; an…
Risk Factors, the 2026 Tightening, and Practical Responses. Why Hong Kong Bank Account Applications Get Rejected: Risk Factors, the 2026 Tightening, and Practical Responses.
The value-added tax (Imposta sul Valore Aggiunto, VAT) is Italy’s primary indirect tax, levied on the value generated at each stage of the domestic supply chain. The Italian VAT regime is regulated by the Presidential Decree DPR 633/1972 and fully complies wit…
Recently, many foreign entrepreneurs and high-net-worth individuals operating in China have received information update notices from banks requesting supplementary tax residency declarations. This is not a routine annual review, but a clear signal of the upgrade to CRS 2.0,…
Environmental, social, and governance (ESG) related risks are becoming more relevant to the ability of entities to exist and thrive. As the landscape of risks continuously changes, it is imperative for entities to have a strong ERM system in place to ensure that strategy …
In China, social insurance contributions are generally calculated based on employees’ salary income, subject to the lower and upper limits announced by local authorities. According to the PRC Social Insurance Law, employers are required to declare and pay social insuranc…
