中国税制变化对物流成本影响分析(英文).pptVIP

PALDMS-346304-v2 Legal, Tax and Customs Developments Affecting China Supply Chain Structures Agenda KEY DEVELOPMENTS New Enterprise Income Tax Law Customs Export VAT Refund Rate Adjustments Prohibition and Restrictions in Contract Manufacturing Agenda IMPACT ON CHINA SUPPLY CHAIN STRUCTURES Holding Company Considerations Manufacturing Procurement Distribution After Sales China’s Economic Development Rapid Industrialization ‘Factory of the World’ to ‘Consumer Market of the World’ Persistent Concerns with Trading Relationships Desire to upgrade and move up ‘value chain’ China uses a comprehensive toolbox of tax, customs and regulatory mechanisms in an attempt to achieve these goals. Key Developments Tax Revenues – 2007 New Enterprise Income Tax Law(Tax Unification) Background to the unification Two different enterprise income tax systems for foreign-invested enterprises (“FIEs”) and for enterprises with domestic investment only. New law unifies income tax treatment of all enterprises and eliminates certain incentives for FIEs. New law passed on 16 March 2007 and will be effective on 1 January 2008. Implementing regulations to be issued. Important changes for foreign investors Tax rates Tax incentives / grandfathering Collection and enforcement Other changes Tax rates – active income Unified EIT rate: 25% Previous tax rates: 15%, 24%, 33% Grandfathering: gradually increase the rate from previous low rate (15% or 24%) to the unified rate over 5 years for qualified FIEs established before publication of the new law. Planning: look for acquisition targets eligible for grandfathering. Tax rates – passive income Standard withholding tax rate: 20% Current reduced rate of 10% on interest, royalty, rental and capital gain. Exemption of dividend withholding tax? Planning: transfer PRC operation to a tax efficient holding vehicle. Planning: repatriate profits? Tax incentives Tax holiday for manufacturing FIEs and reduced EIT rate for export-oriented FIEs will be abolishe