Announcement on Tax Policies for Pilot Real Estate Investment Trusts (REITs) in the Infrastructure Sector

关于基础设施领域不动产投资信托基金（REITs）试点税收政策的公告

Favorable tax policy is offered to REITS

(Issued by the Ministry of Finance and the State Taxation Administration on January 26, 2022 and effective as of January 1, 2021.)

(财政部及税务总局于二零二二年一月二十六日发布，自二零二一年一月一日起施行。)

We hereby announce relevant tax policies to support the pilot project for real estate investment trusts in the infrastructure sector (Infrastructure REITs) as follows:

为支持基础设施领域不动产投资信托基金（以下称基础设施REITs）试点，现将有关税收政策公告如下：

1 .  Where the originator transfers the infrastructure assets to the project company and acquires corresponding equity in the project company before the establishment of an Infrastructure REIT, special tax treatment shall apply, i.e. the tax basis for the acquisition of the infrastructure assets by the project company shall be determined as the original tax basis for the infrastructure assets; and the tax basis for the acquisition of the equity in the project company by the originator shall be determined as the original tax basis for the infrastructure assets. No income is recognized by the originator or the project company and no enterprise income tax is levied.

一、设立基础设施REITs前，原始权益人向项目公司划转基础设施资产相应取得项目公司股权，适用特殊性税务处理，即项目公司取得基础设施资产的计税基础，以基础设施资产的原计税基础确定；原始权益人取得项目公司股权的计税基础，以基础设施资产的原计税基础确定。原始权益人和项目公司不确认所得，不征收企业所得税。

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