The Beijing National Tax Bureau has recently published the details of a major controlled foreign corporation (CFC) case involving CNY 300 million in undistributed profits of a Hong Kong subsidiary wholly owned by China resident enterprise.
Under China's general CFC rules, if a resident enterprise itself, or together with other Chinese residents, controls a foreign enterprise in a jurisdiction with a significantly lower effective tax rate (50% or less than China’s EIT rate, i.e. less than 12…