Official Reply on the Issue of the Income Tax Treatment of Sale-leaseback Transactions by Foreign-invested Enterprises that Engage in Real Property Development

关于从事房地产开发的外商投资企业售后回租业务所得税处理问题的批复

The Reply clarifies under which case an enterprise assigns interests in, or risks attaching to, an asset through a sale-leaseback transaction it shall be deemed to have transferred all or part of the ownership of the immovable property.

(Issued by the State Administration of Taxation on May 31 2007.)

(国家税务总局于二零零七年五月三十一日发布。)

Guo Shui Han [2007] No.603

国税函 [2007] 603号

Hunan Provincial Office of the State Administration of Taxation:

湖南省国家税务局：

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