Substance test
Announcement 7 targets arrangements lacking reasonable commercial purpose that indirectly transfer PRC taxable property. Listed-market and qualifying internal-restructuring exclusions/safe harbors require exact conditions.
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Announcement 7 targets arrangements lacking reasonable commercial purpose that indirectly transfer PRC taxable property. Listed-market and qualifying internal-restructuring exclusions/safe harbors require exact conditions.
Use the output to organize the facts, then confirm the source, evidence, local implementation and available remedy before acting.