China Tax & Investment Consultants Ltd

INCOME TAX FOR FOREIGN INVESTMENT ENTERPRISE (FIE)
AND FOREIGN ENTERPRISE (FE)

TAX TREATY CREDIT FOR FOREIGN INVESTOR

	Bilateral credit
	Under the PRC tax treaty, the corporate level income tax paid by the foreign investment enterprise are eligible for an indirect tax credit for foreign investors in their home jurisdictions.

	Tax sparing credit
	A Foreign Investment Enterprise who is a resident of a PRC treaty country is deemed to have paid the income tax under the indirect tax sparing credit provision in respect of any PRC tax concession and tax breaks being granted. However, there is no tax sparing credit provision in the treaty concluded between the PRC and the USA.

Major PRC treaty countries by geographic area
	Asia Australia, Cyprus, India, Indonesia, Japan, Malaysia, New Zealand, Pakistan, the Philippines, Singapore, Sri Lanka, Thailand, and Vietnam; Europe Austria, Britain, Belgium, Denmark, Finland, France, Germany, Greece, Luxembourg, Norway, Sweden, Ireland, Italy, the Netherlands, Portugal, Slovakia, Spain, Switzerland, and the Russia; Africa South Africa, Mauritius, Egypt, and Nigeria America Canada, USA, Brazil, Cuba and Jamaica Hong Kong residents are entitled to benefits of avoiding double income tax under the Arrangements concluded between the PRC Central People's Government and the Government of the Hong Kong Special Economic Region.