Doing Business in China www.bakertillyinternational.com Contents 1 Fact Sheet 2 2 Business Entities and Accounting 2.1 General 2.2 Representative Office (RO) 2.3 Wholly Foreign-owned Enterprise (WFOE) 2.4 Equity Joint Venture (EJV) 2.5 Contractual Joint Venture (CJV) 2.6 Other Business Entities 2.7 Audit and Accounting Requirements 2.8 Filing Requirements 4 4 4 5 5 6 6 6 7 3 Finance and Investment 3.1 Investment Approval 3.2 Exchange Control 3.3 Banking and Sources of Finance 3.4 Investment Incentives 3.5 Research and Development (R&D) 3.6 Tariffs 8 8 9 9 10 10 10 4 Employment Regulations 4.1 General Employment Matters 4.2 Visas and Permits 11 11 12 5 Taxation 5.1 Corporate Income Taxes 5.2 Personal Taxes 5.3 Employment Related Costs and Taxes 5.4 Withholding Taxes 5.5 Value Added Tax (VAT) 5.6 Business Tax 5.7 Other Taxes 5.8 Tax Incentives for Businesses 13 13 14 15 15 16 16 17 18 Member Firm Contact Details 20 2 1 Fact Sheet Geography Location: East Asia Area:9,596,960km2 Land boundaries: Afghanistan, Bhutan, Burma, India, Kazakhstan, Kyrgyzstan, Laos, Mongolia, Nepal, North Korea, Pakistan, Russia, Tajikistan and Vietnam Coastline: Pacific Ocean; more specifically, East China Sea, Yellow Sea, South China Sea and Korea Bay Climate: A notable monsoonal trait. Cold and dry in the winter; hot and wet in the summer. It is hotter and more humid in the south and colder and dryer in the north. The January mean temperature is much lower than that experienced in other countries at the same latitude, whereas mean temperature in July is much higher Terrain: Generally, highlands in the west and lowlands in the east. Various land forms made up of highlands (33%), plateaux (26%), basins (19%), plains (12%) and moors (10%) Time zone: GMT +8 People Population: 1,351m (2012) Ethnic groups: Han people in the majority, with 55 ethnic minorities Religion: Buddhism is the predominant faith and Islam the second largest faith. China allows freedom of worship for other religions Language: The official language is Mandarin (Pu Tung Hwa). Within the PRC there are a number of local dialects and ethnic languages spoken and there are parts of China where Mandarin is not the predominant or preferred spoken language. Written Chinese characters are consistent and understood throughout China. English is spoken by a small percentage of the population but is the most common language used in international business. English is now taught in all junior schools as a second language Doing Business in China 3 Government Country name: People’s Republic of China (PRC) Government type: Communist Capital: Beijing, with a population exceeding 20m Administrative divisions: The Chinese mainland is made up of 22 provinces, five autonomous regions and four municipalities directly under the central government Political situation The Constitution of the PRC stipulates that the country’s central state organs comprise six components: the National People’s Congress (NPC), the Presidency of the PRC, the State Council, the Central Military Commission, the Supreme People’s Court and the Supreme People’s Procuratorate. The NPC is the fundamental decision-making body in China. The Communist Party of China (CPC) is the country’s sole political party in power. The General Secretary of the CPC is the Head of State. Economy GDP – per capita: US$6,188 (2012) GDP – real growth rate: 7.8% (2012) Unemployment: 4.1% (2012) Currency: The Renminbi (RMB), denominated in units of Yuan (¥), Jiao and Fen (one Yuan equals 10 Jiao or 100 Fen). The exchange rate is managed (fixed on a daily basis) against all currencies 4 2 Business Entities and Accounting 2.1 General The most common legal structures used for establishing a presence in the PRC are: • A representative office (RO) • A wholly foreign-owned enterprise (WFOE) • An equity joint venture (EJV) • A contractual joint venture (CJV). An investor establishing a foreign investment enterprise (FIE) is required to meet a variety of minimum capital requirements, including: • ¥500,000 typically required as minimum share capital, although this can increase to ¥1m where VAT registration is required. • US dollar or yuan paid-up capital requirements depending on the industry in which the investment is being made. • Paid-up capital requirements dependent on the total US dollar amount of the investment being approved. 2.2 Representative Office (RO) An RO cannot invest in, or carry on business in, the PRC, nor can it enter into sales or trade on its own account. It can act only as the representative of its head office in a liaison, quality control, sourcing or similar role. Approval and registration of an RO normally takes two to three weeks and is often used as an intermediary step before establishing a WFOE. Doing Business in China 5 2.3 Wholly Foreign-owned Enterprise (WFOE) The legal entity most frequently used by foreign investors is the WFOE, which is a limited liability company that is wholly owned by foreign investors. However, the law and regulations restrict or prohibit the establishment of WFOEs in certain industries. The legal representative of a WFOE has the power to represent the enterprise and, therefore, the articles of association must spell out, in detail, the scope of the representative’s authority. Capital may be contributed in cash or tangible assets with a minimum 30% cash contribution. When capital is contributed in instalments, an immediate 15% contribution is required and the final instalment must be within two years of issuing the business licence. There is no mandatory management structure for a WFOE, but the articles of association must define the structure in detail and specify procedures for termination, liquidation and amendment of the articles. 2.4 Equity Joint Venture (EJV) An EJV is typically used for long-term projects and is formed jointly by foreign and Chinese companies, enterprises, other economic organisations or individuals. The duration of an EJV usually ranges from 10 to 30 years, but can be 50 years or longer with government approval. The duration of an EJV can be extended when it expires. An EJV is typically a limited liability company. The profits and losses of an EJV are allocated according to the ratio of capital contributions made by the EJV partners. A minimum 25% foreign participation is required. Capital is contributed in the form of cash although, under certain conditions, tangible or intangible assets can be contributed. An EJV must have at least three directors, including a chairman and a vice chairman. The directors must meet at least once a year and make all major decisions. Some decisions require the unanimous agreement of the directors. An EJV does not fix the number of managers, but must include a general manager (no nationality requirement) and a deputy general manager. 6 2.5 Contractual Joint Venture (CJV) CJV structures are often adopted for shorter-term projects or build-operatetransfer projects, and are formed with joint capital or terms of co-operation between foreign and Chinese companies, enterprises, other economic organisations or individuals. A CJV can register as a company with limited liability, but this is not mandatory. Capital is contributed in an agreed ratio and may take the form of cash, land use rights, technology (patented or unpatented), materials and equipment, trademarks and other property rights. Parties to a CJV share profit in the ratio determined in the contract and not according to investors’ respective contributions. A CJV is governed by the Law on Co-operative Joint Ventures and requires a venture to have either a board of directors or a joint management committee. The chairman of the board or the head of the management committee serves as the CJV’s legal representative. 2.6 Other Business Entities The PRC has established the legal framework for other business structures such as partnerships, but foreign investors have preferred to use investment vehicles that provide them with greater legal certainty. 2.7 Audit and Accounting Requirements The mandatory accounting year is the calendar year. All FIEs are required to be audited. Financial statements must be presented in Chinese in accordance with Chinese generally accepted accounting principles (GAAP). The PRC currently uses two accounting systems: • New Chinese GAAP (NCGAAP), which is close to IFRS • Old Chinese Accounting Standards (OCAS) and Accounting Regulations for Business Enterprises (ARBE). Companies listed on Chinese stock exchanges and unlisted large and medium size companies are required to adopt NCGAAP. Unlisted small companies still apply OCAS and ARBE. A conversion date for unlisted small companies has yet to be set. Doing Business in China 7 2.8 Filing Requirements The annual business licence renewal process requires all enterprises in China (including FIEs) to submit their financial statements and auditor’s report (together with other documents specified in their business licence) to the Administration of Industry and Commerce (AIC) in the taxpayer’s area for annual inspection. The law provides that annual inspections are to be carried out by the AIC from 1 March to 30 June each year. 8 3 Finance and Investment 3.1 Investment Approval Traditionally, foreign investors had to obtain approval before establishing or investing in the PRC; however, in order to encourage foreign direct investment into China, the rules have been relaxed to some extent. The PRC maintains a Foreign Investment Catalogue (FIC) to guide the approval of FIEs. The FIC encourages investment in modern agriculture, high technology industries, modern services and infrastructure. Regulations categorise foreign investment as either encouraged, restricted, prohibited or permitted. The FIC provides details of the first three categories, while permitted projects are deemed to be all projects not listed. The Catalogue of Encouraged Hi-tech Products for Foreign Investment encourages investment in electronic information, software and outsourcing services, aviation and spaceflight, advanced manufacture, biology, medicine and medical appliances, new materials, new and high efficiency energy, environmental protection, earth and ocean sciences, and applied nuclear energy technology. The FIE approval process typically involves 15 separate applications divided into: • Investment approval, and • Business registration. The approval and registration process is completed at provincial government level, although some investment proposals may require national government approval. The application process can vary significantly from location to location and can take two to three months, or longer, to complete. A business licence must be renewed annually. Doing Business in China 9 3.2 Exchange Control Foreign exchange controls allow convertibility on current account (ie foreign exchange used by the enterprise for daily recurring transactions in the ordinary course of business), impose controls on capital items (ie imports and exports of capital), and supervise and manage the foreign exchange business of financial institutions. Technically, China has removed all restrictions on payments by enterprises for imports, labour and services, repayment of interest on foreign debt and the repatriation of profits, but offshore remittances require approval by the State Administration of Foreign Exchange (SAFE). With the exception of trade goods, approval is not provided unless an application is supported by documentation including proof of taxation. Approval of transactions on capital account is closely scrutinised by SAFE and the investment approval authorities, and can be a time consuming process. 3.3 Banking and Sources of Finance The banking system comprises: state-owned or controlled banks, other banks, and foreign-funded banks. State-owned and controlled banks constitute the largest component of the banking system. Foreign banks can get approval to incorporate in China and operate as Chinese banks. A number of foreign banks have incorporated in the PRC. Non-bank financial institutions include: trust and investment corporations, securities companies, insurance companies, finance companies, leasing companies and credit unions. The banking system is highly liquid and most forms of business financing are available. A foreign investor may find obtaining funding difficult or more expensive until they have established good banking relationships. The government closely manages the banking system and may impose lending or capital restrictions on individual banks or the banking sector, affecting the availability of financing from time to time. 10 3.4 Investment Incentives Investment incentives are largely tax driven and are focused on designated industries. See 5.8. 3.5 Research and Development (R&D) For R&D expenses incurred in the development of new technologies, new products or new production techniques, a 50% additional deduction may be granted if the expenses are not capitalised as intangible assets but are instead recorded directly in an enterprise’s income statement for the current period. If the expenditures are capitalised as intangible assets, 150% of the expenditures can be amortised. Research expenditure for new technology, new products and new craftsmanship are allowed an additional deduction of 50% of actual cost. 3.6 Tariffs Import duties are generally imposed on imported goods. The rates imposed are either general rates or preferential rates where the PRC has a reciprocal tariff agreement with the exporting country. Customs duty and VAT are exempt on equipment imports by an FIE which form part of its total approved investment. Exemptions may also be available for imports encouraged under the FIC. Export products manufactured by an enterprise, except those prohibited from exportation by the state and those subject to other state regulations, are exempt from export tariffs. Imports necessary for an enterprise to produce exports are regarded by Customs as bonded commodities. 11 4 Employment Regulations For employment tax considerations, see 5.3. 4.1 General Employment Matters 4.1.1 Employment law Until 2008, employment law was governed by the Labour Law of the PRC. While this law continues to remain in force today, employment law was reformed with the introduction of the Employment Contract Law (ECL), which sought to improve working conditions in China. In the case of contracts signed before 2008, the provisions of the ECL supersede those of the Labour Law should any dispute arise. Various other laws provide for such matters as mediation and arbitration in employment disputes, and employee representation. 4.1.2 Employment contract The law stipulates that employment contracts should be in writing. Where a contract in writing is not provided before employment, one must be concluded and provided within one month of the employee commencing work. Employment contracts must contain information as prescribed by the ECL, including: • The duration of the contract • Scope of work • Place of work • Working hours, rest and leave •Pay • Social insurance, and • Labour protection, working conditions and protection against occupational hazards. A probation period can be included in the contract. Standard working hours are eight hours per day, up to 40 hours per week. While overtime pay is specified in the Labour Law (at rates of between 150% and 300% of usual pay), employers can seek government approval to introduce alternative working hours systems that eliminate or restrict entitlement to overtime payments. 12 Employees are entitled to paid annual leave of between five and 15 working days, depending on their length of service, plus public holidays. Minimum wages are set at local government level. 4.1.3 Employee representation All trade unions are affiliated with the All-China Federation of Trade Unions, which effectively brings them under government control. However, unions in China tend to act as intermediaries between employers and employees, rather than working in the full interests of the employees. 4.2 Visas and Permits Foreigners visiting China for business must approach Chinese business associates and obtain a letter of invitation. A visa may then be obtained from an embassy or consulate. An FIE intending to employ an expatriate must apply to the authorities for an Employment Licence for Expatriates (ELE). Once the ELE is issued, the FIE may then apply for the Professional Visa Notification (PVN). The expatriate then applies for a Professional Visa with a copy of the PVN and the original of the ELE. Within 15 days of entering China, the expatriate must apply for an Employment Certificate (EC), which is used by the expatriate to apply for a Residence Certificate (RC). It is common for an expatriate employee to be in China on a business visa during this process. Foreigners seeking employment can enter China on an occupational visa, but can only be employed after obtaining the EC and RC. 13 5 Taxation 5.1 Corporate Income Taxes There is no definition of a company in Chinese tax law and taxes on trading income are imposed on business enterprises generally. Resident enterprises, defined as those which are established in China, or which are established in a foreign country but which have their place of effective management in China, are taxed on their worldwide income. Other enterprises are taxed only on their income from sources in China, subject to the terms of any relevant double tax treaty. The Special Administrative Regions of Hong Kong and Macau are not within the tax jurisdiction of China, and enterprises established in the Regions are subject to tax in China only if they have their place of effective management there or if they have income arising there. The general rate of corporate income tax is 25%. A reduced rate of 20% applies to enterprises with annual taxable income of less than ¥300,000. Other requirements must also be met, including • Total assets of less than ¥30m and fewer than 100 employees for industrial enterprises, or • Total assets of less than ¥10m and fewer than 80 employees for all other enterprises. Micro-enterprises (ie businesses with annual income of no more than ¥60,000 for calendar years 2012 to 2015 (¥30,000 previously)) benefit from a 50% exemption based on the 20% rate, giving an effective rate of 10%. Capital gains are taxed in the same way as income. Enterprises may carry forward losses for relief against future profits for up to five years. There is no provision for losses to be carried back for relief against earlier profits. There is no tax consolidation facility for groups of enterprises. The tax year is the calendar year; businesses cannot choose an alternative tax year. Tax returns must be filed within five months of the tax year-end (ie for tax year 2013, by 31 May 2014). Tax liabilities must be paid on an estimated basis each month or quarter. Any balancing amount due must be paid within five months of the tax year-end (thus, for tax year 2013, the balancing payment is due by 31 May 2014). The period for filing final tax returns can be extended in special circumstances, provided it is applied for within the specified filing period. 14 5.2 Personal Taxes Resident individuals are generally taxed on their worldwide income. Foreign nationals who are resident in China for less than five years are usually taxed only on their income from sources within China. Non-resident individuals are taxed only on their income from sources in China. Resident individuals are taxed at the following rates on wage and salary income: Monthly Taxable Income Tax Rate ¥0 – ¥1,500 3% ¥1,501 – ¥4,500 10% ¥4,501 – ¥9,000 20% ¥9,001 – ¥35,000 25% ¥35,001 – ¥55,000 30% ¥55,001 – ¥80,000 35% Over ¥80,000 45% For income from individual industrial and commercial households (ie private businesses and sole proprietors), the tax rates are as below: Annual Taxable Income Tax Rate ¥0 – ¥15,000 5% ¥15,001 – ¥30,000 10% ¥30,001 – ¥60,000 20% ¥60,001 – ¥100,000 30% Over ¥100,000 35% The standard monthly deduction against taxable income is ¥3,500 with an additional monthly deduction of ¥1,300 for certain individuals, such as foreign nationals and expatriate employees. Capital gains are taxed as income, with the exception of gains realised from selling property, in which case the gain is taxed at 20%. There are no inheritance, gift or wealth taxes. Doing Business in China 15 5.3 Employment Related Costs and Taxes 5.3.1 Fringe benefits Fringe benefits which do not represent “money” or “money’s worth”, and are not convertible into cash, are not taxed in the hands of the employee. The manner in which benefits are granted should not amount to the discharging of an employee’s liability by an employer. Otherwise, the benefit is taxable. For expatriate employees, housing, meal, laundry, relocation, language training, a portion of child education and reasonable travel allowances received in noncash form, or as reimbursement for expenses incurred, are provisionally exempt from individual income tax in China. 5.3.2 Social security costs Employers are generally required to make social security contributions to insurance funds for pensions, medical, work-related injuries, unemployment and maternity. Employees are generally required to make social security contributions to insurance funds for pension, medical and unemployment. The rates vary from city to city. 5.4 Withholding Taxes 5.4.1 Domestic payments Dividends, interest and royalties paid to resident companies, or to non-resident companies with a permanent establishment (PE) in China, are generally included in taxable corporate income (headline rate 25%). Certain qualifying dividends from equity investment gains are exempt. Where such payments are made to individuals, a general withholding tax rate of 20% applies, with the following exceptions: • Interest payments made from savings accounts are exempt • The rate in relation to listed shares depends on the period for which they are held: • 5% if held for more than one year • 10% if held for between one month and one year, and • 20% if held for one month or less. 16 5.4.2 Payments abroad Dividends, interest and royalties paid to non-resident companies without a PE in China, or with a PE to which incomes are not attributed, are subject to a 10% withholding tax (reduced from 20% for an unspecified period since 2000). Dividends paid out of pre-2008 profits are exempt from withholding tax. The payment of technical assistance fees can in some circumstances be classed as royalties and accordingly become subject to withholding tax. For payments made to recipients in countries with which China has a double tax treaty, the withholding tax may be reduced or eliminated. 5.5 Value Added Tax (VAT) VAT is levied on the selling price of goods and of some services, and on the value of imported goods. Business enterprises generally must register for the tax, but individuals with a low turnover are exempt. There is no registration threshold for resident and non-resident businesses. The standard VAT rate is 17%, although reduced rates of 0%, 3%, 6%, 11% and 13% apply to certain goods and services. Enterprises can usually recover the VAT with which they themselves are charged, but there are some exceptions. Period VAT returns are filed monthly. The deadline for filing is 15 days after the end of the period. From 1 August 2013, VAT has been suspended for small businesses with monthly turnover below ¥20,000 and for cross-border services; at the time of announcements, no end dates were given. 5.6 Business Tax Business tax is charged on the selling price of goods and services which are not subject to VAT, but with several exceptions. Rates vary, and include 3% for construction, telecommunication and transportation services, 5% for sales of property and for certain service industries, and up to 20% for the entertainment industry. Unlike VAT, enterprises cannot recover the business tax with which they themselves are charged. From 1 August 2013, business tax has been suspended for small businesses with monthly turnover below ¥20,000; at the time of announcement, no end date was given. Doing Business in China 17 5.7 Other Taxes 5.7.1 Deed tax Contracts for the sale or lease of real estate are subject to deed tax at rates ranging from 3% to 5%. The tax is generally based on the transaction value or the market value. 5.7.2 Land appreciation tax Gains made from the transfer of real estate rights are subject to land appreciation tax at rates ranging from 30% to 60%. 5.7.3 Other real estate taxes Enterprises occupying real estate in towns and cities must pay an urban land use tax to the local government authority. The tax is calculated by reference to the size of the property occupied, with the rate per square metre varying depending on the size of the town or city. Enterprises must also pay a house property tax to local authorities. The tax applies to all buildings occupied, not only houses, and is based on the assessed value of the property or the rental income it generates. 5.7.4 Stamp duty Stamp duty is charged on documents evidencing transactions, generally at rates from 0.005% to 0.1% of the capital value. Transfers of shares listed on a domestic stock exchange are charged at 0.1% of their value. 5.7.5 Environment tax There is currently no general tax based on environmental issues, although there is a limited pollutant emission surcharge in place. 5.7.6 Consumption tax Consumption (excise) tax is imposed at various rates on a number of goods, including tobacco, alcoholic drinks, certain automobiles and motors, petrol, diesel oil, vehicle tyres, cosmetics, luxury jewellery and fireworks. 18 5.8 Tax Incentives for Businesses 5.8.1 Research and development (R&D) expenditure For R&D expenses incurred in the development of new technologies, new products or new production techniques, a 50% additional deduction may be granted if the expenses are not capitalised as intangible assets but are instead recorded directly in an enterprise’s income statement for the current period. If the expenditures are capitalised as intangible assets, 150% of the expenditures can be amortised. Enterprises which produce high technology goods or services falling within a government prescribed list are eligible for a reduced 15% rate of tax provided conditions are satisfied. The conditions are extensive, and relate, for example, to the ratio of R&D expenditure to turnover, the proportion which sales of high technology goods and services bears to total turnover, the ratio of research staff to total staff, and the proportion of research staff with a university degree. 5.8.2 Environmental sector Businesses providing energy-saving services are eligible for full corporate income tax exemptions in the first three years, and a corporate income tax rate of 12.5% for the second three years. Eligible years are calculated from the first year in which business income arises. Those in the energy saving, environment protection and production safety industries can use 10% of their investments in equipment to offset their income tax payable, and this can be carried forward for five years. Businesses in the comprehensive resources utilisation sector (which aims to recycle and reuse industrial waste materials) can benefit from a 10% corporate income tax exemption. Doing Business in China 19 5.8.3 Other incentives Businesses involved in agrarian industries and those appointed as reserve stockholders of grain, oil, sugar, cotton and meat benefit from corporate income tax exemptions. A reduced income tax rate of 15% applies for high or new technology ventures eligible for key support from the state. Venture capital enterprises may be eligible for a 70% reduction of the amount invested from their taxable income if they have invested in encouraged small or medium-sized high technology enterprises for more than two years. Newly established software or integrated circuit design businesses are exempted from corporate income tax for the first two profitable years and enjoy a 50% reduction in corporate income tax for the subsequent three years. Businesses engaged in agriculture, fisheries and forestry are subject to reduced rates of tax. Also, businesses undertaking public infrastructure and environmental protection projects can benefit from reduced rates of tax on their income from those projects. 25 Farringdon Street London EC4A 4AB United Kingdom T: +44 (0)20 3201 8800 F: +44 (0)20 3201 8801 info@bakertillyinternational.com www.bakertillyinternational.com Baker Tilly is the trademark of the UK firm, Baker Tilly UK Group LLP, used under licence. Like us on Facebook © 2013 Baker Tilly International Limited, all rights reserved Join our group