The "Announcement" pointed out that for cross-border e-commerce enterprises in the cross-border e-commerce comprehensive test area, if they meet certain conditions at the same time, they will try out the approved corporate income tax method. Cross-border e-commerce enterprises approved for collection in the comprehensive test area shall accurately account for the total amount of income and approve the collection of enterprise income tax by means of taxable income rate. The rate of taxable income is determined uniformly at 4 per cent. The announcement will come into force on January 1, 2020.

The Interpretation pointed out that the cross-border e-commerce enterprises approved and collected in the comprehensive test area can mainly enjoy the following two types of preferential policies: First, they meet the ''Notice of the Ministry of Finance and the State Administration of Taxation on the Implementation of Inclusive Tax Reduction Policies for Small and Micro Enterprises'' (Caishui [2019] No. 13) The preferential policy conditions for small and low-profit enterprises can enjoy the preferential income tax policies for small and low-profit enterprises; second, if the income obtained belongs to the tax-free income stipulated in Article 26 of the the People's Republic of China Enterprise income tax Law, it can enjoy the relevant preferential policies for tax-free income.

The following is the original text of the announcement and the interpretation of the original text:

Announcement of the State Administration of Taxation on Issues concerning the Verification and Collection of Income Tax on Retail Export Enterprises in Cross-border E-commerce Comprehensive Pilot Zones

State Administration of Taxation Announcement No. 36 of 2019

In order to support the healthy development of cross-border e-commerce and promote the innovation of foreign trade models, effectively cooperate with the implementation of the Notice of the Ministry of Finance, the State Administration of Taxation, the Ministry of Commerce, the General Administration of Customs on the Tax Policies for Retail Exports in Cross-border E-commerce Comprehensive Pilot Zones (Caishui [2018] No. 103), the relevant issues concerning the approved collection of enterprise income tax by cross-border e-commerce retail export enterprises (hereinafter referred to as "cross-border e-commerce enterprises") in the cross-border e-commerce comprehensive pilot zone (hereinafter referred to as "comprehensive pilot zone") are hereby announced as follows:

1. the cross-border e-commerce enterprises in the comprehensive test area and meeting the following conditions at the same time, the enterprise income tax shall be approved on a trial basis: (1) registered in the comprehensive test area and registered the date, name, unit of measurement, quantity, unit price and amount of export goods on the cross-border e-commerce online comprehensive service platform of the place of registration; (II) the export goods to go through the e-commerce export declaration procedures through the customs of the place where the comprehensive test area is located; if the (III) export goods have not obtained a valid purchase certificate, the value-added tax and consumption tax are exempt from tax.

Cross-border e-commerce enterprises approved for collection in the 2. comprehensive test area shall accurately account for the total amount of income and approve the collection of enterprise income tax by means of taxable income rate. The rate of taxable income is determined uniformly at 4 per cent.

The 3. tax authorities shall, in accordance with the relevant provisions, promptly complete the appraisal of the cross-border e-commerce enterprises in the comprehensive test area to approve the collection of enterprise income tax.

If the cross-border e-commerce enterprises in the 4. comprehensive test area meet the preferential policy conditions for small low-profit enterprises, they can enjoy the preferential income tax policy for small low-profit enterprises; the income they obtain belongs to Article 26 of the the People's Republic of China Enterprise Income Tax Law Those who have the tax-free income can enjoy the preferential policy of tax-free income.

5. The comprehensive pilot zone referred to in this announcement refers to the comprehensive pilot zone for cross-border e-commerce approved by the State Council; the cross-border e-commerce enterprises referred to in this announcement refer to self-built cross-border e-commerce sales platforms or use third-party cross-border e-commerce Enterprises that carry out e-commerce exports on the platform.

6. This announcement shall come into force on January 1, 2020. It is hereby announced. Interpretation of the State Administration of Taxation on October 26, 2019 on the Announcement of the State Administration of Taxation on Issues Concerning the Approval and Collection of Income Tax for Retail Export Enterprises in Cross-border E-commerce Comprehensive Pilot Zones Recently, the State Administration of Taxation issued the Announcement on Issues Concerning the Approval and Collection of Income Tax for Retail Export Enterprises in Cross-border E-commerce Comprehensive Pilot Zones (hereinafter referred to as the Announcement).

Now read as follows:

1. Background In September 2018, the Ministry of Finance, the State Administration of Taxation, the Ministry of Commerce and the General Administration of Customs jointly issued the Notice on Tax Policies for Retail Export Goods in the Cross-border E-commerce Comprehensive Pilot Zone (Caishui [2018] No. 103), for cross-border e-commerce retail export enterprises (hereinafter referred to as "cross-border e-commerce enterprises") in the cross-border e-commerce comprehensive pilot zone (hereinafter referred to as "comprehensive test zone") that have not obtained valid purchase certificates, where they meet the prescribed conditions, exports are exempt from value-added tax and consumption tax (hereinafter referred to as "no ticket tax exemption" policy). In order to support the development of new forms of cross-border e-commerce, promote the innovation of foreign trade models, and cooperate with the implementation of the "no ticket tax exemption" policy, the executive meeting of the State Council decided to introduce more convenient income tax collection methods for enterprises. Therefore, the State Administration of Taxation issued the announcement to further clarify the issues related to the approval and collection of income tax of cross-border e-commerce enterprises, so as to promote cross-border e-commerce enterprises to better carry out export business.

The main content of the 2. "Announcement" stipulates matters related to the approved collection of corporate income tax by cross-border e-commerce enterprises in the comprehensive test area in terms of the approved collection scope, conditions, methods, procedures, and preferential policies. E-commerce companies provide more convenient operation methods.

The scope of (I) approved collection is to cooperate with the implementation of the "no ticket tax exemption" policy. Cross-border e-commerce enterprises refer to enterprises that meet the requirements of Caishui [2018] No. 103, that is, enterprises that build their own cross-border e-commerce sales platforms or use third-party cross-border e-commerce platforms to carry out e-commerce exports.

(II) approved collection conditions Cross-border e-commerce enterprises through the business platform to export goods, is a new form of development in recent years. In order to encourage the development of cross-border e-commerce, in view of the actual situation that cross-border e-commerce enterprises cannot obtain purchase invoices for export goods, the Ministry of Finance, the Ministry of Commerce, the General Administration of Customs and the State Administration of Taxation jointly issued document No. 103 [2018]. Cross-border e-commerce enterprises meet the prescribed conditions and can try out the policy of "tax exemption without tickets. For these enterprises, in accordance with the provisions of this announcement, the enterprise income tax can be levied by means of verification on a trial basis.

(III) approved collection method As cross-border e-commerce enterprises can accurately account for their income, in order to simplify the operation of taxpayers and tax authorities, cross-border e-commerce enterprises approved for collection in the comprehensive test area uniformly adopt the approved taxable income rate method to approve the collection of enterprise income tax. At the same time, considering that the procurement and sales of export goods of cross-border e-commerce enterprises are mainly carried out through e-commerce platforms, and the differences between different regions are small, in order to further reduce the burden on enterprises and promote the development of export business, the comprehensive test area is approved and collected The taxable income rate of cross-border e-commerce enterprises is in accordance with the "Notice of the State Administration of Taxation on Printing and Distributing the" Enterprise Income Tax Collection Measures "(Trial)" (2008 No. 30), the minimum taxable income rate for wholesale and retail trade in the State Administration of Taxation Announcement No. 31 of 2018) is determined, I .e. uniformly implemented at 4%.

Cross-border e-commerce enterprises and tax authorities in the comprehensive test area of (IV) verification and collection procedures shall handle the relevant business of verification and collection in accordance with the relevant provisions. The tax authorities shall promptly complete the verification and collection and appraisal of cross-border e-commerce enterprises in the comprehensive test area, and cross-border e-commerce enterprises shall declare and pay taxes on time.

The cross-border e-commerce enterprises approved and collected in the comprehensive pilot zone of (V) preferential policies can mainly enjoy the following two types of preferential policies: first, those who meet the preferential policy conditions for small and low-profit enterprises stipulated in the notice of the Ministry of Finance and the State Administration of Taxation on the implementation of inclusive tax reduction and exemption policies for small and micro Enterprises (No. 13, 2019) can enjoy the preferential income tax policies for small and low-profit enterprises. If the above provisions are changed, from its provisions.

Second, if the income obtained belongs to the tax-free income stipulated in Article 26 of the the People's Republic of China Enterprise income tax Law, it can enjoy the relevant preferential policies for tax-free income.

3. Implementation Time The Announcement will be implemented from January 1, 2020. Attachment: "Notice on Tax Policies for Retail Export Goods in Cross-border E-commerce Comprehensive Pilot Zone" Caishui [2018] No. 103 In September 2018, the Ministry of Finance issued the "Notice on Tax Policies for Retail Export Goods in Cross-border E-commerce Comprehensive Pilot Zone", for export enterprises in cross-border e-commerce comprehensive pilot zone to export goods that have not obtained valid purchase certificates and meet certain conditions, trial value-added tax and consumption tax exemption policies.

The following is the original text of the ''Notice'': Notice on Tax Policies for Retail Export Goods in the Cross-border E-commerce Comprehensive Pilot Zone. Finance Departments (bureaus) and commerce authorities of all provinces, autonomous regions, municipalities directly under the Central Government, and cities under separate state planning, the State Administration of Taxation The tax bureaus of all provinces, autonomous regions, municipalities directly under the Central Government, and cities under separate state planning, the offices of special commissioners of the State Administration of the State Administration of the General Administration of Taxation in various regions, Guangdong, the General Administration of Customs, Guangdong, and: in order to further promote the healthy and rapid development of cross-border e-commerce and cultivate new trade formats and new models, the cross-border e-commerce retail exports in the cross-border e-commerce comprehensive pilot zone (hereinafter referred to as the comprehensive test zone) are now

(hereinafter referred to as e-commerce export) goods related tax policy notice as follows:

1. to the comprehensive test area e-commerce export enterprises export goods that have not obtained a valid purchase certificate, and meet the following conditions, the trial value-added tax, consumption tax exemption policy:

(I) e-commerce export enterprises are registered in the comprehensive test zone and register the export date, name of goods, unit of measurement, quantity, unit price and amount at the cross-border e-commerce online integrated service platform at the place of registration.

(II) export goods through the comprehensive test area of the local customs for e-commerce export declaration procedures.

(III) export goods do not belong to the goods for which the Ministry of Finance and the State Administration of Taxation have explicitly canceled the export tax refund (exemption) in accordance with the decision of the State Council.

The offices of the leading groups for the construction of the comprehensive test areas of the 2. and the competent commercial departments shall coordinate and promote the communication and cooperation between departments and the implementation of relevant policies, accelerate the establishment of an e-commerce export statistical monitoring system, and promote the healthy and rapid development of cross-border e-commerce.

The General Administration of Customs of 3. regularly transmits electronic information on the declaration list of e-commerce export commodities to the General Administration of Taxation. The tax authorities of each comprehensive test area shall strengthen the duty-free management of export goods according to the electronic information of the export commodity declaration list cleared by the General Administration of Taxation. The specific tax exemption management measures shall be formulated by the provincial tax department in consultation with the financial and commercial departments.

4. The comprehensive pilot zone referred to in this Notice refers to the comprehensive pilot zone for cross-border e-commerce approved by the State Council; the e-commerce export enterprises referred to in this Notice refer to self-built cross-border e-commerce sales platforms or use third-party cross-border e-commerce platforms Units and individual industrial and commercial households that carry out e-commerce exports.

5. This notice shall be implemented as of October 1, 2018, and the specific date shall be subject to the export date indicated in the export commodity declaration list. Ministry of Finance, General Administration of Taxation, Ministry of Commerce, General Administration of Customs, September 28, 2018

Source: China Cross-border E-commerce Comprehensive Pilot Zone