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　　Ministry of Finance and State Administration of Taxation Announcement No. 64 of 2019

Further clarify the corporate income tax policy applicable to perpetual bonds，According to the relevant provisions of the "Enterprise Income Tax Law of the People's Republic of China" and its implementation regulations，The relevant issues are now announced as follows:

一、Perpetual bonds issued by enterprises，Dividends can be applied、Dividend corporate income tax policy，That is: the interest income from perpetual bonds obtained by investors is dividends、Bonus nature，Processed in accordance with the relevant provisions of the current corporate income tax policy，Among them，Both the issuer and the investor are resident enterprises，Perpetual bond interest income can be applied to dividends between resident enterprises stipulated in the Corporate Income Tax Law、Dividends and other equity investment income are exempt from corporate income tax;At the same time, interest dafabet online sports betting apppayments on perpetual bonds paid by the issuer shall not be deducted before corporate income tax。

二、Enterprises issue perpetual bonds that meet specified conditions，The corporate income tax policy can also be applied according to the bond interest，That is: the interest paid by the issuer on perpetual bonds is allowed to be deducted before its corporate income tax;The interest income from perpetual bonds obtained by investors shall be taxed in accordance with the law。

Three、Perpetual bonds that meet the prescribed conditions as mentioned in Article 2 of this announcement，refers to perpetual bonds that meet more than 5 (inclusive) of the following conditions:

(1) The invested enterprise has the obligation to repay the investment;

(2) There is a clearly agreed interest rate and interest payment frequency;

(3) There is a certain investment period;

(4) The investor does not have ownership of the net assets of the invested enterprise;

(5) The investor does not participate in the daily production and operation activities of the invested enterprise;

(6) The invested enterprise can redeem，Or it can be redeemed after meeting certain conditions;

(7) The invested enterprise will include the investment as a liability;

(8) The investment does not bear the same operating risks as the shareholders of the invested enterprise;

(9) The order of settlement of the investment is before the shares held by the shareholders of the invested enterprise。

Four、Enterprises issue perpetual bonds，The applicable tax treatment shall be reported to the stock exchange、Disclosed dafabet online betting websiteto investors in issuance documents in issuance markets such as the inter-bank bond market。

　五、Once the tax treatment method of each perpetual bond product by the enterprise that issues perpetual bonds is determined，No changes allowed。The tax treatment method adopted by the enterprise for perpetual bonds is inconsistent with the accounting method，Issuer、Investors must make corresponding tax adjustments during tax treatment。

Six、The perpetual bonds referred to in this announcement refer to the bonds approved by the National Development and Reform Commission、People's Bank of China、China Banking and Insurance Regulatory Commission、Approved by China Securities Regulatory Commission，Or registered with the National Association of Financial Market Institutional Investors、Registration of securities self-regulatory organizations authorized by China Securities Regulatory Commission，Issued in accordance with legal procedures、Bonds with redemption (renewal) options or no clear maturity date，Including renewable corporate bonds、Renewable corporate bonds、Perpetual debt financing instruments (including perpetual notes)、No fixed term capital bonds, etc.。

Seven、This announcement will come into effect on January 1, 2019。

Ministry of Finance

State Administration of Taxation

April 16, 2019

　Keywords: income tax

Document number:

Document size: Ministry of Finance and State Administration of Taxation Announcement No. 64 of 2019

Issuing department: Ministry of Finance