China Expands Rules on Indirect Transfers of Chinese Assets

On 6 February 2015, China's State Administration of Taxation (SAT) issued Public Notice 7 (2015), which covers the taxation of indirect transfers of assets by non-resident enterprises. Public Notice 7 expands upon and generally replaces the provisions for taxing indirect transfer of China resident enterprises as introduced in Circular 698 (2009), and SAT Bulletin 24 (2011). Key aspects of Notice 7 are summarized as follows.

Recharacterization and Scope of Assets

An indirect transfer of ass…