By Jian Li; Alan Paisey;
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Additional resources for Transfer Pricing Audits in China by Jian Li (2007-02-15)
Taxes are imposed on the proﬁts repatriated by subsidiaries operating in host countries to their parent companies in their home countries. Such intermediate taxes are typically withholding taxes in the host country as the source of the proﬁts. 3. Taxation on proﬁts repatriated to the home country. Taxes are imposed on proﬁts in the home country of a parent company that have been repatriated from its operating subsidiaries or other entities in other countries. Additionally, in some cases home country taxes may be imposed on foreign proﬁts which have not been repatriated – in circumstances where anti-tax haven legislation may apply (Tomsett, 1989, pp.
Cn Note: The Eastern Region includes: Beijing, Tianjin, Hebei, Liaoning, Shanghai, Jiangsu, Guangdong, Zhejiang, Fujian, Shandong, and Hainan. The Central Region includes: Shanxi, Jilin, Heilongjiang, Anhui, Jiangxi, Shanxi, Henan, Hubei, and Hunan. The Western Region includes: Inner Mongolia, Guangxi, Sichuan, Chongqing, Guizhou, Yunnan, Shanxi, Gansu, Qinghai, Ningxia, Xinjiang, and Tibet. Hong Kong has been actually a recycling of capital from mainland China, which sought to take advantage of the preferential policies offered to foreign investors.
Taxes on dividends Dividends paid to an overseas parent company from the proﬁts of a foreign investment enterprise are generally exempt from withholding tax, but the dividends cannot be deductible. Likewise, proﬁts repatriated from a branch in China to its overseas head ofﬁce are also exempt. • Taxes on interest Interest paid on loans to an overseas investment company is deductible provided the interest is charged at a normal market rate. The interest received by the overseas investment company is subject to the basic withholding tax of 20%.