China's State Administration of Taxation has published Circular 64/2018 from the Ministry of Finance, which provides that expenses in connection with research and development (R&D) activities outsourced to foreign companies may be eligible for the R&D super deduction effective from 1 January 2018. The Circular provides that up to 80% of expenses incurred in relation to such outsourcing may be eligible, provided that the expenses do not exceed two-thirds of the Chinese enterprises tot…