19 February 2016 China issues first advance tax ruling on cross border transaction A municipal state tax bureau in Jiangsu Province in China recently issued an advance tax ruling on a multinational company's restructuring plan in which one non-Chinese holding company will merge into another non-Chinese holding company, resulting in direct transfers of equity of two Chinese subsidiaries. After reviewing the planned transaction, the tax authorities issued a written confirmation to the taxpayer stating that the proposed cross border merger would as be eligible for tax deferral treatment under Circular 59. A Tax Alert prepared by Ernst & Young's China Tax Desk in New York, and attached below, provides additional details. Document ID: 2016-0347 |
