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Tax

Deloitte GFSI tax professionals offer innovative solutions for clients in the Chinese financial services sectors. The opening of China's banking industry leads to significant inbound investment opportunities for foreign banks to tap into domestic banking market. On the other hand, local Chinese banks with abundant foreign currency reserves are venturing outbound in the face of increasing competition from foreign institutions. Deloitte GFSI tax team can help both local and foreign banks to clear the potential hurdles in the ever-changing tax environments to realise their business objectives.

Services offered

Outbound investment tax services
  • Structuring advisory

Assist to formulate outbound investment structures. The structures encompass financing planning, cash repatriation and exit strategies as well as minimizing global effective tax rates.

  • Foreign tax credit (FTC) maximisation

The new China Enterprise Income Tax (EIT) Law allows taxpayers to claim indirect FTC. We can advise on ways to maximise FTC utilisation.

  • Controlled foreign enterprise (CFC)

The new EIT Law also introduces CFC rules. We can advise on ways to minimise CFC exposure and assist on the related compliance reporting.

  • Tax planning and tax implication advisory in respect of new financial products
Inbound investment tax services
  • Structuring advisory

Assist to formulate tax-efficient cross-border investment structures. The structures will encompass financing planning, cash repatriation and exit strategies as well as minimising global effective tax rates.

  • Tax residency and permanent establishment (PE) risk minimisation strategy

The new EIT Law expands the definition of tax resident to increase foreign enterprise with place of effective management in China and the Chinese tax authorities have stepped up enforcement efforts in relation to PE. Our specialists can assist investors to avoid and mitigate the related risks.

  • Tax planning and tax implication advisory in respect of conversion from branches to legal entities of foreign banks in China
  • Tax structuring and reorganisation for non-performing loans and assets
  • Tax planning and tax implication advisory in respect of new financial products
Mergers & acquisitions tax services
  • Tax due diligence
  • Planning and implementing acquisition tax structure to minimise the tax costs in the acquisition, post acquisition cash flow as well as exiting from the investment.
  • Cash tax analysis
  • Review of sales and purchase agreement to identify opportunities to reduce purchase price and risks
  • Post-transaction integration assistance

Assist new investors to resolve historical issues and integrate the acquired business to achieve investors' business objectives

Transfer pricing
  • Income attribution for banks and other financial institutions
  • Cost sharing analysis
  • Contemporaneous documentation, advisory and compliance
Compliance services
  • Corporate tax compliance services, including handling Inland Revenue Department enquiries, lodging offshore claims
  • Personal tax compliance services
  • Tax compliance health check

 

Contact us

  • Johnny Foun
    Tax Partner, Shanghai
  • Davy Yun
    Tax Director, Hong Kong SAR
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