On 30 June 2015, China's State Administration of Taxation issued Public Notice (2015) 48, which amends the rules for special tax treatment (no recognition of gain or loss) available for corporate reorganizations. The changes apply for tax years beginning in 2015.
Under Notice 48, the special tax filing for approval of special tax treatment is no longer required. In order to apply special tax treatment, the parties to a reorganization are required to submit designated forms, schedules, and su…