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SAT issues clarification on non-resident enterprises electing for “special tax treatment” ...

SAT issues clarification on non-resident enterpri...

China Tax Alert - Issue 36, December 2013

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SAT issues clarification on non-resident enterprises electing for “special tax treatment” of PRC equity interest transfers

On 12 December 2013, the State Administration of Taxation issued the Circular 72 to provide more specific guidance on the recordal filing requirement for “special tax treatment” of certain cross-border corporate re-organisation involving PRC equity interest transfers. The Circular 72 clarifies the fulfillment of administrative procedures for the election of “special tax treatment” on the two types of cross-border Qualifying Transfers by way of recordal filing with PRC tax authorities and it also supplements and updates the previous requirements of Circular 59 and Circular 698.

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