Tax Update Breakfast Seminar

"Tax Consideration for Indirect Equity Transfer"

At the end of 2009, the State Administration of Taxation (SAT) issued Circular Guo Sui Han, Circular 698. This addresses the tax issues for equity transfer by non-China Tax Resident Enterprises. Circular 698 is one of the steps taken by the Chinese tax authorities in tackling various tax avoidance arrangements and transactions. Circular 698 has had a significant impact on many foreign investors that use offshore holding companies to invest in China.
Tracy Zhang will highlight the recent updates on indirect equity transfer, looking at the recent issue of SAT Announcement 24, which clarifies Circular 698 notification and taxation requirements of indirect disposal of equity interests. The update also discusses whether the offshore indirect disposal rules will be extended to include disposals by non-residents. Tracy will also look at the legal framework of indirect equity transfer transactions as well as giving examples of real life cases.

"RMB (Re-)Investments by Foreign Investors in China"
As of late, new circulars concerning RMB (re-)investments by foreign investors were published, namely Yin Fa [2011] No. 145 and PBOC Publication [2011] No. 1 and Hui Zi Han [2011] No. 7 which may impact considerations on how to structure RMB (re-)investments in China by foreign investors.
Susanne Rademacher will highlight the general legal framework for such (re-)investments which have been issued during the recent years and analyze what foreign investors need to bear in mind in connection with the newly published announcements and circulars when (re-)investing RMB in China.

Speakers

Tracy Zhang, KPMG.
Tracy joined KPMG Beijing office in 1996. She was seconded to KPMG Qingdao office and functioned as the head of the local tax practice in 2006. From April 2007 till July 2008, she worked with International Corporate Tax practice in KPMG New York and Financial Service practice in KPMG London respectively.
Tracy is a PRC regulatory and tax expert on China investment related issues. Since 2004, she has been functioning as one of the leaders of the Financial Service tax team in KPMG Beijing, looking after domestic and foreign banks, funds and insurance clients. She has also been involved in developing structures for foreign investor`s investments into China, tax due diligences reviews in connection with M&A transactions and advising on cross border transactions.

Susanne Rademacher, Beiten Burkhardt.
Susanne Rademacher is an equity partner and head of office of Beiten Burkhardt`s
Beijing office and has been resident in China since 2001. Her areas of activity comprise corporate as well as foreign direct investment in China. She particularly advises clients from the automotive, chemical, machinery, renewable energy and hotel/hospitality industries. Susanne Rademacher studied law at the Universities of Cologne/Germany and Lausanne/Switzerland and studied Chinese language at the Beijing Foreign Languages University with a scholarship of the European Union and the China Ministry of Commerce. She is admitted to the German Bar in Cologne and is a foreign registered lawyer with the China Ministry of Justice. She has been working with Beiten Burkhardt in China since 2002.

Date & Time:

July 26^th 2011, 08:00 a.m.

Venue:

Kempinski Hotel

Beijing Lufthansa Center
50 Liangmaqiao Road, Chaoyang District, Beijing
Tel: +86 10 6465 3388

朝阳区亮马桥路50号, 100125 北京

Entrance Fee:

200 RMB for Members and 350 RMB for non-Members

Registration:

The registration to the event must be made by email at the address info@cameraitacina.com before Thursday 21^st July 2011 at 12.00 p.m.noon. Please add the following information:
• Name
• Company Name
• Job title
• Mobile phone number

Information:

If you have any questions or need further information please contact the CICC at info@cameraitacina.com

Best regards,

CICC