China: Guidance for offshore indirect transfers

China: Guidance for offshore indirect transfers

China’s tax administration issued guidance for the administration and implementation of new indirect offshore disposal rules.


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The guidance—Shui Zong Han [2015] No. 68, or “Circular 68”—provides instructions to local tax authorities concerning:

  • An official receipt for transaction reporting of a taxpayer indirect offshore disposal (thus providing certainty to taxpayers that they have discharged their reporting obligations)
  • Consolidated tax filing for indirect transfers at multiple locations
  • General anti-avoidance rule (GAAR) case evaluation at the “verification” stage
  • Procedures for initiating a GAAR investigation and adjustment
  • Case follow-up

Read a June 2015 report prepared by the KPMG member firm in China: Implementation guidance issued for Announcement 7 indirect transfers

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