China's New Business Income Tax
Shielding Non-China Income From the Expansive Enterprise Income Tax
Plus: The Impact of IRS Contract Manufacturing Regs for U.S. Operations in China
Recording of a 90-minute premium CLE webinar with Q&A
Outline
- New PRC Enterprise Income Tax (EIT)
- Effective Jan. 1, 2008
- Resident enterprises: Worldwide income taxable on net basis
- Place of incorporation
- Place of effective management
- Non-resident enterprises
- With an establishment (PE) in China; taxable on net basis
- China-sourced income
- Effectively connected income
- Without an establishment in China but with China-sourced income; taxable on gross basis
- With an establishment (PE) in China; taxable on net basis
- Special tax adjustments
- Transfer pricing, cost-sharing and APA
- Thin capitalization
- CFC
- GAAR
- High tech-related incentives
- Branch tax filing
- Consolidated EIT returns for all branches
- Concerns on EIT flowing into locations of head offices
- EIT allocation among head offices and branches
- Opportunities For Foreign Companies To Restructure Chinese Operations On Tax-Free Basis
- State Administration of Taxation notice Guoshuifa (1997) 207 (Notice)
- Transferring interest in foreign investment enterprise at cost to another group company
- Will dividend-withholding tax exemption continue?
- Restructuring PRC investments through tax-haven holding companies
- Impact of Proposed New IRS Regs On Contract Manufacturing And Subpart F Income
- Application of manufacturing exception
- Application of branch rule to multi-branch manufacturing operations
- Extensive discussion of case study
Benefits
The panel will gives you the benefit of their experience and analysis on these and other top tax priorities:
- Understanding crucial aspects of the enterprise income tax and the associated rules and circulars, so that your company can protect its income from taxation to the maximum possible.
- Identifying tax opportunities and pitfalls in the Chinese marketplace offered by the proposed U.S. contract manufacturing regs.
- Planning tax strategies to deal with anti-avoidance provisions and transfer pricing guidance from China.
Following speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.
Faculty

Peng Tao
Of Counsel
DLA Piper
His practice focuses on tax and transfer pricing issues in China. He formerly worked in the People's Republic of... | Read More
His practice focuses on tax and transfer pricing issues in China. He formerly worked in the People's Republic of China's Bureau of Legislative Affairs for five years and for two other international law firms.
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Alan Granwell
Partner
DLA Piper
He has been practicing in international taxation, and more specifically tax planning and controversies, for more than... | Read More
He has been practicing in international taxation, and more specifically tax planning and controversies, for more than 35 years. He formerly was an international tax counsel and director of the Treasury Department's Office of International Tax Affairs.
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Melanie Chen
Managing Director for China Region Group
UHY Advisors
She specializes in cross-border transactions in China, Hong Kong and Taiwan and advises U.S. companies on complex tax... | Read More
She specializes in cross-border transactions in China, Hong Kong and Taiwan and advises U.S. companies on complex tax issues in the region. Previously, she worked for Deloitte Touche Tohmatsu in Shanghai and for a law firm in Beijing.
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Strafford will process CLE credit for one person on each recording. All formats include course handouts.
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