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Offshore Equity Transactions: Implications of Recent Changes to Corporate Tax Law in China

June 2010 - Finance. Legal Developments by Ogier .

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The Chinese State Administration of Taxation (“SAT”) issued Circular [2009] No. 698 (“Circular 698”) on 10 December 2009. Circular 698 addresses various tax issues on equity transfers by non-Chinese tax resident enterprises. It applies retroactively from 1 January 2008 and covers direct and indirect sales by non-Chinese tax resident enterprises of unlisted shares of Chinese tax resident enterprises.

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