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On June 27, 2025, China’s Ministry of Finance (MOF) has introduced a new tax policy to encourage overseas investors to reinvest profits earned from Chinese resident enterprises back into the domestic market.
Effective from January 1, 2025, to December 31, 2028, the policy aims to boost foreign direct investment (FDI) and channel capital toward high-priority sectors such as advanced manufacturing, green energy, and innovation-driven industries.
What are the key benefits?
- Overseas investors can claim a 10% tax credit on reinvested profits, which can offset annual taxable income in China.
- Unused tax credits can be carried forward indefinitely, providing flexibility for investors with cyclical profits or complex holding structures.
- This new tax policy is compatible with tax treaties benefits. Investors from countries with tax treaties with China can enjoy both lower withholding tax rates and the new reinvestment credit.
Who is eligible?
To ensure that the tax credit supports high-quality and productive investment, China’s new reinvestment tax policy sets out clear eligibility rules for both investors (1) and the nature of the reinvestment (2).
- Eligible Investors
The policy applies to overseas investors, including companies and individuals, that receive dividends or profit distributions from Chinese resident enterprises. To qualify:
- The distributed profits must derive from retained earnings (namely, accumulated and not previously reinvested or withdrawn); and
- The recipient must be a non-resident enterprise under Chinese tax rules.
- Eligible Forms of Reinvestment
The reinvestment must be eligible domestic direct investment, including:
- Capital increases to existing Chinese subsidiaries;
- Greenfield investments (namely, setting up new enterprises);
- Acquisitions of non-listed domestic companies; and
- Purchases, capital increase, or acquisition of listed shares, but only if the investment qualifies as a strategic investment under securities regulations.
To determine your eligibility for this new tax policy on reinvested profits and to assist with the application process, please contact us through contact@orbis-alliance.com.