Tax Analysis. PRC Tax. International Tax Services. NTC Tax Analysis Issue P68/ April 2009
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1 Tax Tax Analysis. NTC Tax Analysis Issue P68/ April 2009 Authors: Shanghai Leonard Khaw Tel: Lu Qiang Senior Manager Tel: Ye Hong Senior Manager Tel: For more information on the subject, please contact: International Tax Services National Leader (Shanghai) Leonard Khaw Tel: Northern Region (Beijing) Nancy Marsh Tel: Eastern Region (Shanghai) Vicky Wang Tel: Southern Region (Hong Kong SAR) Sharon Lam Tel: PRC Tax International Tax Services SAT Issues Guidance on Tax Residence Status of Chinese-Controlled Offshore Companies The State Administration of Taxation (SAT) issued a Notice on 22 April 2009 that provides guidance on the determination of tax residence status of Chinese-controlled offshore companies under the new place of effective management and control rule in the 2008 Enterprise Income Tax Law (EIT Law) (Guoshuifa [2009] 82). The Notice may have a significant impact on Chinese companies listed on a foreign stock exchange and the round tripping of investments. Background Chinese tax residents pay EIT on worldwide income. The EIT Law defines a Chinese tax resident enterprise as either an enterprise that is incorporated in China or an enterprise that is incorporated outside China but that has its place of effective management and control in China. The EIT Implementation Rules (Regulations) define the place of effective management and control as the "place where the overall management and control over manufacturing and business operations, personnel, accounting and property [etc.] of an enterprise are, in substance, exercised." Under this rule, an enterprise incorporated in a foreign country or territory would be regarded as a Chinese tax resident -- and thus be required to pay EIT in China on its worldwide income -- if it is effectively managed and controlled in China. The Notice sets out detailed rules for determining whether a Chinesecontrolled offshore incorporated enterprise is a tax resident of China, describes the tax implications of such an enterprise being regarded as a tax resident and sets out the procedures for an assessment of residence status by the relevant local tax bureau. The provisions of the Notice apply retroactively as from 1 January 2008.
2 Key Points of the Notice 1) Definition of a Chinese-controlled offshore incorporated enterprise Article 1 defines a Chinese-controlled offshore incorporated enterprise as an enterprise that is incorporated under the laws of a foreign country or territory and has a domestic (i.e. a Chinese) enterprise or enterprise group as its primary controlling shareholder. 2) Criteria for determining the place of effective management and control Article 2 provides that a Chinese-controlled offshore incorporated enterprise will be regarded as a Chinese tax resident by virtue of having a place of effective management and control in China and it will be subject to EIT on its worldwide income if all of the following conditions are satisfied: The primary location of the day-to-day operational management is exercised in China; Decisions relating to the enterprise's financial and human resource matters are made or are subject to approval by organizations or personnel in China; The enterprise's primary assets, accounting books and records, company seals, board and shareholder meeting resolutions are located or maintained in China; and 50% or more of voting board members or senior executives habitually reside in China. Article 3 further provides that the substance-over-form principle will be applied in determining the place of effective management and control. 3) Tax implications of Chinese tax residence status According to article 4 of the Notice, dividends distributed by a Chinese tax resident are exempt from income tax in the hands of an offshore incorporated Chinese tax resident under article 26 of the EIT Law and article 83 of the Regulations. Also according to article 4, dividends distributed by an offshore incorporated Chinese tax resident are deemed to be China-source income under article 7(4) of the Regulations. According to article 5 of the Notice, a Chinese subsidiary of an offshore incorporated Chinese tax resident retains its status as a foreign-invested enterprise. According to article 6 of the Notice, an offshore incorporated Chinese tax resident will not be treated as a controlled foreign company under the EIT Law; however, the status of the foreign subsidiaries it controls will be determined separately. 4) Assessment of Chinese tax resident status Article 7 of the Notice provides that a Chinese-controlled offshore incorporated enterprise may apply to the local tax bureau in charge of its main Chinese shareholder for a determination of its status. In the absence of a request, that tax bureau reserves the right to make a determination of the status of a Chinese-controlled offshore incorporated enterprise based on the information available to the bureau. In both instances, a final determination is made by the SAT. 5) Determination of tax residence status under a tax treaty Article 8 of the Notice stipulates that the status of a dual resident company is to be determined in accordance with the provisions of an applicable tax treaty. 2 Analysis 1) Purposes of the Notice It is interesting that the Notice only covers Chinese-controlled offshore incorporated enterprises. It defines such enterprises as those that are themselves controlled by Chinese enterprises. It is unclear whether foreign-incorporated enterprises that are controlled by Chinese individuals or foreign-
3 incorporated enterprises that are controlled by foreign companies also fall within the scope of this Notice. Based on the language of the Notice, it seems that the SAT does not intend for it to apply to these categories of companies. On the surface, it would appear that many Chinese based companies with offshore investments would be subject to the Notice because the ultimate decision-making resides in the headquarters in China. However, a careful reading shows that the rules are flexible, allowing the SAT considerable discretion to interpret the Notice and select which types of Chinese companies to target. On the other hand, the rules do not unduly constrain companies in relation to the organization of their governance and management structures. Companies too have reasonable room for maneuver in this regard. 2) Determining the "primary controlling shareholder" As noted above, a Chinese-controlled offshore incorporated enterprise is defined as an enterprise that is incorporated under the laws of a foreign country or territory and that has a Chinese enterprise or enterprise group as its primary controlling shareholder. The question thus arises as to what constitutes a "primary controlling shareholder." Would "control" be determined by the ownership percentage, voting rights or de facto control? Many offshore listed Chinese groups comprise an offshore special purpose listed parent that holds the group's Chinese operations through Chinese subsidiaries: would the listed parent be viewed as a Chinese-controlled offshore incorporated enterprise if Chinese investors retain management control or remain significant shareholders in the group? The answer is unclear based on the language of the Notice. 3) Lack of measurable conditions for determining Chinese tax residence status According to article 2 of the Notice, if an enterprise fails to satisfy one of the conditions set forth above, it will not be regarded as a Chinese tax resident. This disqualification is provided for despite the obvious lack of measurable criteria in the Notice. For example, it is unclear what constitutes the "primary location" for exercising the day-to-day operational management, what constitutes "habitually resides in China" and what factors are to be used to determine whether an enterprise's primary assets are located in China. For an offshore holding company whose only activity is to hold the investments in China, would its assets (being the shares in the Chinese subsidiaries) be viewed as entirely located in China? Despite these ambiguities, it would seem that SAT s intention is to avoid being too specific so that it would have more discretion to apply the substance-over-form principle. 4) Tax consequences for dividend distributions received by a foreign shareholder of the offshore incorporated Chinese tax resident According to the Notice, dividends received by a foreign shareholder of the offshore incorporated Chinese tax resident would be subject to Chinese withholding tax, which could result in adverse tax consequences for a foreign shareholder if the dividends would otherwise not be subject to tax. 5) Tax implications of capital gains derived by a foreign shareholder from the disposition of shares in the offshore incorporated Chinese tax resident The Notice is silent on how capital gains derived by a foreign shareholder from the disposition of shares in the offshore incorporated Chinese tax resident should be taxed. Following the logic of article 4 (treatment of dividends), it is reasonable to conclude that such gains would be treated as China-source income and, therefore, subject to capital gains tax under the EIT Law. Recommendations The first step that a company should take is to determine whether it is a Chinese-controlled offshore incorporated company that is covered by the Notice. Being a Chinese tax resident may not necessarily result in negative tax consequences. A company should evaluate the tax implications based on its own circumstances before taking any action with regard to the Notice. The provisions of the Notice are effective from 1 January 2008; accordingly, a company which is covered by the Notice should not only review its position going forward, but also its status in respect of the 2008 year. The objective of the review is to determine whether the company has an exposure resulting from the Notice which requires a provision in its financial statements for that year. For example, the company, if found to be a tax resident of China, would be subject to tax in China on its non-china source income. That income would not be subject to tax in China otherwise. 33
4 All companies should ensure that procedures and controls are put in place such that its tax status (tax resident in China, or non-resident) is not inadvertently affected by actions of its shareholders, board, management and employees. It should be noted that the determination concerning the status of a company is made by reference to "substance" and not "form." Nonetheless, in setting up such procedures and controls, particular regard should be paid to the factors set out in the Notice: the composition of the board and the locations in which board members and senior management of the company reside; locations in which board and management functions are exercised and decisions made; and locations in which the company seals, books and records are kept. We recommend that procedures and controls be clearly documented, and regular reviews be carried out in order to ensure that they are adhered to. Companies should now also look ahead and consider what evidence they would have to substantiate who exercises board, management and other relevant functions, makes relevant decisions, and locations in which such functions are exercised and decisions are made. All companies are well advised to ensure that they are able, if questioned or challenged, to produce compelling evidence to support their respective preferred positions concerning their tax status. 4
5 Tax Analysis is published for the clients and professionals of the Hong Kong and Chinese Mainland offices of Deloitte Touche Tohmatsu. The contents are of a general nature only. Readers are advised to consult their tax advisors before acting on any information contained in this newsletter. For more information or advice on the above subject or analysis of other tax issues, please contact: Beijing Kevin Ng Tel: Fax: kevng@deloitte.com.cn Hong Kong SAR Ryan Chang Tel: Fax: ryanchang@deloitte.com.hk Shenzhen Lawrence Cheung Tel: Fax: lacheung@deloitte.com.cn Dalian Constant Tse Tel: Fax: contse@deloitte.com.cn Macau SAR Quin Va Tel: Fax: quiva@deloitte.com.hk Suzhou Frank Xu Tel: Fax: frakxu@deloitte.com.cn Guangzhou Daisy Kwun Tel: Fax: dkwun@deloitte.com.cn Nanjing Frank Xu Tel: Fax: frakxu@deloitte.com.cn Tianjin Vincent Lo Tel: Fax: vinlo@deloitte.com.cn Hangzhou Frank Xu Tel: Fax: frakxu@deloitte.com.cn Shanghai Vivian Jiang Tel: Fax: vivjiang@deloitte.com.cn About the Deloitte China National Tax Technical Centre The Deloitte China National Tax Technical Centre ( NTC ) was established in 2006 to continuously improve the quality of Deloitte China s tax services, to better serve the clients, and to help Deloitte China s tax team excel. The Deloitte China NTC prepares and publishes Tax Analysis, Tax News, etc. These publications include introduction and commentaries on newly issued tax legislations, regulations and circulars from technical perspectives. The Deloitte China NTC also conducts research studies and analysis and provides professional opinions on ambiguous and complex issues. For more information, please contact: National Tax Technical Centre ntc@deloitte.com.cn Eastern Region Zhang Li Guo National Director & Tel: Fax: ligzhang@deloitte.com.cn Southern Region (Chinese Mainland) Miao Zhi Cheng Director Tel: Fax: zmiao@deloitte.com.cn Northern Region Angela Zhang Tel: Fax: angelazhang@deloitte.com.cn Southern Region (Hong Kong SAR) Davy Yun Director Tel: Fax: dyun@deloitte.com.hk If you prefer to receive future issues by soft copy or update us with your new correspondence details, please notify Wandy Luk by either at wanluk@deloitte.com.hk or by fax to
6 Deloitte provides audit, tax, consulting, and financial advisory services to public and private clients spanning multiple industries. With a globally connected network of member firms in 140 countries, Deloitte brings world-class capabilities and deep local expertise to help clients succeed wherever they operate. Deloitte s 165,000 professionals are committed to becoming the standard of excellence. Deloitte s professionals are unified by a collaborative culture that fosters integrity, outstanding value to markets and clients, commitment to each other, and strength from cultural diversity. They enjoy an environment of continuous learning, challenging experiences, and enriching career opportunities. Deloitte s professionals are dedicated to strengthening corporate responsibility, building public trust, and making a positive impact in their communities. Deloitte refers to one or more of Deloitte Touche Tohmatsu, a Swiss Verein, and its network of member firms, each of which is a legally separate and independent entity. Please see for a detailed description of the legal structure of Deloitte Touche Tohmatsu and its member firms. Deloitte s China practice provides services through a number of legal entities and those entities are members of Deloitte Touche Tohmatsu (Swiss Verein). We are one of the leading professional services providers in the Chinese Mainland, Hong Kong SAR and Macau SAR. We have over 8,000 people in 11 offices including Beijing, Dalian, Guangzhou, Hangzhou, Hong Kong, Macau, Nanjing, Shanghai, Shenzhen, Suzhou and Tianjin. As early as 1917, we opened an office in Shanghai. Backed by our global network, we deliver a full range of audit, tax, consulting and financial advisory services to national, multinational and growth enterprise clients in China. We have considerable experience in China and have been a significant contributor to the development of China s accounting standards, taxation system and local professional accountants. We also provide services to around one-third of all companies listed on the Stock Exchange of Hong Kong. These materials and the information contained herein are provided by Deloitte Touche Tohmatsu and are intended to provide general information on a particular subject or subjects and are not an exhaustive treatment of such subject(s). Accordingly, the information in these materials is not intended to constitute accounting, tax, legal, investment, consulting, or other professional advice or services. The information is not intended to be relied upon as the sole basis for any decision which may affect you or your business. Before making any decision or taking any action that might affect your personal finances or business, you should consult a qualified professional adviser. These materials and the information contained therein are provided as is, and Deloitte Touche Tohmatsu makes no express or implied representations or warranties regarding these materials or the information contained therein. Without limiting the foregoing, Deloitte Touche Tohmatsu does not warrant that the materials or information contained therein will be error-free or will meet any particular criteria of performance or quality. Deloitte Touche Tohmatsu expressly disclaims all implied warranties, including, without limitation, warranties of merchantability, title, fitness for a particular purpose, noninfringement, compatibility, security, and accuracy. Your use of these materials and information contained therein is at your own risk, and you assume full responsibility and risk of loss resulting from the use thereof. Deloitte Touche Tohmatsu will not be liable for any special, indirect, incidental, consequential, or punitive damages or any other damages whatsoever, whether in an action of contract, statute, tort (including, without limitation, negligence), or otherwise, relating to the use of these materials or the information contained therein. If any of the foregoing is not fully enforceable for any reason, the remainder shall nonetheless continue to apply Deloitte Touche Tohmatsu in Hong Kong SAR, Deloitte Touche Tohmatsu in Macau SAR, and Deloitte Touche Tohmatsu Certified Public Accountants Ltd. in the Chinese Mainland. All rights reserved. 6
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