Administrative Measures on Enterprise Income Tax of Enterprise Restructuring - 企业重组业务企业所得税管理办法
Released on July 26, 2010 and effective on January 1, 2010
Following the Circular on Issues Concerning the Enterprise Income Tax Treatment on Enterprise Restructuring issued by the Ministry of Finance (MOF) and the State Administration of Taxation (“SAT”) in April, 2009 (“Tax Circular 59”), the SAT issued a Public Notice regarding the Administrative Measures on Enterprise Income Tax of Enterprise Restructuring" on July 26, 2010 (“Tax Notice 4”), which is effective retrospectively to January 1, 2010. Tax Circular 4 provides detailed guidance on documentation and procedural requirements for enterprise income tax issues in corporate restructuring under the Circular 59, including common tax treatment, management of enterprise restructuring, special tax treatment of enterprise restructuring, tax management of cross-broad restructuring.