On 12 March 2013, Jiangsu provincial tax authority published a letter of the State Administration of Taxation (SAT), in response to requests of local tax authorities, and a plan of tax assessment (a kind of instruction) on its website. The letter, enumerated as Shui Zong Han [2013] No. 82, and the plan of tax assessment addressed the case of indirect share transfer conducted by Wal-Mart US. The content of both documents is summarized below.
Facts
Through a BIV subsidiary (MMVI Ch…