Special tax treatment of share transfer by non-resident enterprise

The State Administration of Taxation (SAT) issued an announcement on 11 December 2013 (SAT Gong Gao [2013] No. 72) concerning the special tax treatment of share transfer by a non-resident enterprise. The announcement became effective on the same date as the issuing date and its content is summarized below.
The announcement deals with the special tax treatment referred to in the notice on restructuring of enterprises, Cai Shui [2009] No. 59, and the cases, as described in article 1 paragraphs 1 a…