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Feb 2014, Issue 4

Simplified application approval of Chinese Tax Resident Enterprise - opportunity or challenge?

The Tax Resident Enterprise (TRE) concept was introduced in China's Corporate Income Tax (CIT) Law effective from 2008. Under this framework, the State Administration of Taxation (SAT) provided guidelines for Chinese-capital controlled foreign companies (CCCFCs) to apply for the TRE status (hereinafter referred to as 'deemed TRE'), and required that such deemed TRE status must be approved by the SAT.

Recently, the SAT issued Public Notice [2014] No. 9 (Public Notice 9), delegating the approval power on granting TRE status of CCCFCs to the provincial-level tax bureaus. The simplified application for the Chinese TRE status may bring both opportunities and challenges to relevant companies.

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Peter Ng
China and Hong Kong Tax Leader
Tel: +[86] (21) 2323 1828 Email
Edwin Wong
Tel: +[86] (10) 6533 2100 Email
Charles Lee
China South Tax Leader
Tel: +[86] (755) 8261 8899 Email