1. Forms of Reorganization

Corporate reorganization refers to transactions that significantly change the legal structure or economic structure of an enterprise outside of its daily operating activities, including changes in the legal form of the enterprise, debt Reorganization, equity acquisition, asset acquisition, merger, spin-off, etc.

2. Tax treatment of corporate reorganization

It is divided into two types: general tax treatment and special tax treatment. The tax treatment adopted depends on the size of the transaction amount and the size of the equity transaction. .

(1) General tax treatment

★(2) Special tax treatment

1. If the following conditions are met at the same time, special tax treatment regulations shall apply :

(1) It has a reasonable business purpose and does not have the main purpose of reducing, exempting or deferring the payment of taxes.

(2) The proportion of assets or equity of the part being acquired, merged or spun-off meets the prescribed proportion.

(3) The original substantive operating activities of the reorganized assets will not be changed within 12 consecutive months after the enterprise is reorganized.

(4) The amount of equity payment involved in the restructuring transaction consideration complies with the prescribed proportion.

(5) The original major shareholders who received equity payment during the corporate reorganization shall not transfer the equity acquired within 12 consecutive months after the reorganization.