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Tax Seminar on 2008 Annual Filing and Settlement of Corporate Income Tax and Taxation Rules on Corporate Restructuring

2008 marks the first year for taxpayers to perform the annual tax return filing and settlement of Corporate Income Tax ("CIT") since the new CIT Law has come into effect. The issues and uncertainties faced by tax payers requiring confirmation in the CIT return filing process include:

• differences between the current year's CIT settlement process from previous years
• whether some tax notices issued under the previous Foreign Income Tax Law and Enterprise Income Law remain effective; and
• how to conduct settlement of CIT for head offices and branches in accordance with the new CIT Law etc.

Further, SAT recently issued rules on corporate restructuring and related tax relief for qualifying transactions. These rules are important for taxpayers undergoing group restructuring and M&A transactions.

To assist our clients to gain a better understanding of the CIT return completion and filing process and the corporate restructuring rules, KPMG has organized a special seminar oand have also invited officials from the Shenzhen State Tax Bureau and Shenzhen Local Tax Bureau to attend a question and answer session.

Main content:

• Items that require tax adjustment and focus areas for completion of annual CIT tax returns
• Settlement of CIT of head offices and branches
• Issues surrounding related party transactions and thin capitalization
• "Super" deduction for R&D expenses
• Tax treatment of exchange gains or losses, accrued expenses and deemed sales, etc. and
• Focus areas of tax authorities' review of CIT annual return
• Discussion on CIT implications arising from corporate restructuring and M&A; criteria for qualifying transactions that are entitled to tax relief

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