According to the Notice of State Taxation Administration of The People's Republic of China City, People's Republic of China (PRC) on Printing and Distributing the Implementation Measures for Special Tax Adjustment (for Trial Implementation) (Guo Shui Fa [2009] No.2): Article 9 The relationship mentioned in Article 109 of the Regulations for the Implementation of the Income Tax Law and Article 51 of the Detailed Rules for the Implementation of the Tax Administration Law mainly refers to one of the following relationships between an enterprise and other enterprises, organizations or individuals:

(1) One party directly or indirectly holds more than 25% of the shares of the other party, or both parties directly or indirectly hold more than 25% of the shares of a third party. If one party indirectly holds shares in the other party through the intermediary, as long as one party holds more than 25% of the shares in the intermediary, the shareholding ratio of one party to the other party shall be calculated according to the shareholding ratio of the intermediary to the other party.

(2) The loan funds between one party and the other party (except independent financial institutions) account for more than 50% of the paid-in capital of one party, or more than 65,438+00% of the total loan funds of one party are guaranteed by the other party (except independent financial institutions).

(3) More than half of one party's senior managers (including board members and managers) or at least one senior board member who can control the board of directors is appointed by the other party, or more than half of both parties' senior managers (including board members and managers) or at least one senior board member who can control the board of directors is appointed by a third party.

(4) More than half of the senior management personnel of one party (including board members and managers) are also senior management personnel of the other party, or at least one senior board member of the party that can control the board of directors is also a senior board member of the other party.

(5) The production and operation activities of one party can only be carried out normally if the other party provides industrial property rights, know-how and other concessions.

(6) One party's procurement or sales activities are mainly controlled by the other party.

(7) The acceptance or provision of labor services by one party is mainly controlled by the other party.

(8) One party has substantial control over the production, operation and transaction of the other party, or both parties have other related interests, including that although the shareholding ratio in Item (1) of this article is not reached, one party enjoys basically the same economic interests as the major shareholder of the other party, as well as family and kinship relations.