Taxation of enterprise reorganisation is a current focus of PRC tax authorities. The Circular on Several Issues Concerning the Enterprise Income Tax Treatment of Enterprise Reorganisations ("Circular 59"), issued on 30 April 2009 and retroactive from 1 January 2008, outlines the tax treatment of equity transfers in connection with an enterprise reorganisation. It distinguishes between a deal where capital gains are subject to a withholding tax at the time of the transaction, and one where the ta