Interpretation of Circular No.698/Jian Sun(2)
In accordance with the provisions in Circular No.698, foreign investor whose indirect transfer of Chinese residence enterprises falling into the following two catalogues:
(1) The real tax burden rate of the jurisdiction where the offshore holding company transferred is incorporated is less than 12.5%; or
(2) The jurisdiction where the offshore holding company transferred is incorporated does not acquire income tax from foreign-sourced income.
shall submit the relevant documents as below to the local taxation bureau where the Chinese domestic enterprises being transferred located within 30 days after the execution of Share Transfer Agreement to prove the aforesaid indirect share transfer is for reasonable commercial purpose.
(1) Share Transfer Contract or Agreement.
(2) The relationship between Foreign Investors and Offshore Holding Companies transferred by Foreign Investors regarding finance, operation, purchase and sale, etc;
(3) The situation of the operation, personnel, finance, property of the offshore holding companies transferred by foreign investors;
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