The Ministry of Finance and the State Administration of Taxation (SAT) jointly issued a Notice on 25 December 2009 (Cai Shui [2009] No. 125) clarifying the foreign tax credit (FTC) regime. The Notice retroactively applies from 1 January 2008, and its content is summarized below.
Scope
The Notice applies to resident and non-resident enterprises which are entitled to FTC as provided under Arts. 23 and 24 of the Enterprise Income Tax Law (EITL). Taxes imp…