Questa strategia fornisce maggiore flessibilità e una maggiore protezione alla loro struttura aziendale.

On 19 November 2025, the OECD released the 2025 update to the OECD Model Tax Convention (OECD MTC), introducing significant enhancements aimed at improving tax certainty...

Many companies looking at the Chinese market choose to establish a holding company or special purpose vehicle (SPV) to hold their Chinese investments.

The article discusses the major PRC tax considerations for IP transfers, especially for cross-border IP transactions.

On June 16, 2015, China State Administration of Taxation ("SAT") promulgated the [2015] No. 45 Announcement on Standardizing the Administration of Cost Sharing Agreement.

On 18 March, 2015, China State Administration of Taxation released one important regulation regarding outbound payments by Chinese entities to overseas related parties.

China signed the MLI on 7 June 2017. It has opted out of the MLI's permanent establishment (PE) provisions concerning (i) artificial avoidance of PE status through commissionaire arrangements and similar strategies;

The Macau Special Administrative Region of the People's Republic of China ("Macau SAR") government officially issued the "Implementation Rules for Transfer Pricing" (Administrative Regulation No. 11/2025)...

By now many multinational companies have begun the process of addressing how Financial Accounting Standards Board Interpretation No. 48 ("FIN 48") will apply to their global business.

On 17 September, 2015, China State Administration of Taxation (SAT) released the Discussion Draft for the Implementation Measures for Special Tax Adjustments ("Discussion Draft")...

On 17 September, 2015, China State Administration of Taxation ("SAT") released the Discussion Draft of Implementation Measures for Special Taxation Adjustments ("Discussion Draft")...

This alert provides an in-depth analysis of Announcement 16 mainly from the perspectives of tax authorities' supervision.

The past twenty-four months have seen a surge in the number of increasingly sophisticated merger and acquisition transactions involving U.S., Japanese and European multinationals and China-based companies (listed and unlisted, private and state-owned). Morrison & Foerster has advised on many such transactions, including representing Softbank in connection with Yahoo!’s US$1 billion investment in Softbank’s China affiliates, Alibaba.com and Tao Bao; UPS in its acquisition of its international exp

On January 8, 2009, the State Administration of Taxation ("SAT") issued the Implementation Rules for Special Tax Adjustments (Trial), Guo Shui Fa (2009) No. 2 (the "Rules").

In this issue: Foreign Direct Investment; Foreign Exchange Administration; Intellectual Property Rights; Labor Law; Retailing/Distribution; Securities; State-owned Enterprises; Draft Legislation

Global regulatory frameworks are rapidly evolving to enhance transparency around offshore wealth structures through beneficial ownership registration regimes and enhanced corporate disclosure requirements. As tax authorities gain unprecedented access to information about ultimate controllers and economic beneficiaries behind complex offshore entities, individual investors face increasing scrutiny of their cross-border investment arrangements and compliance obligations.

Global corporate transparency reforms are fundamentally changing how regulators identify beneficial owners behind offshore entities. Through enhanced shareholder registries and beneficial ownership...

在当前全球经济一体化加速推进的背景下，国内企业纷纷将目光投向海外市场，寻求新的增长点。

随着"一带一路"国家政策的推行...

This comprehensive bulletin examines recent tax developments across Asia, including China's VAT reforms, India's controversial Supreme Court ruling on treaty protection, Japan's 2026 tax reform package...