Mainland and Hong Kong Closer Economic Partnership Arrangement
“Circular 698” means Circular No. 698 (国税函698号) issued by the PRC State Administration of Taxation on December 10, 2009, titled “Notice on Strengthening the Administration of Enterprise Income Tax on Income Derived from Equity Transfer Made by Non-Resident Enterprise (关于加强非居民企业股权转让所得企业所得税管理的通知)”, Bulletin No. 7 issued by the PRC State Administration of Taxation on February 3, 2015, titled “Bulletin on Certain Questions relating to the Enterprise Income Tax of Indirect Transfers of Assets by Non-Resident Enterprises (关于非居民企业间接转让财产企业所得税若干问题的公告)”, and any amendment, implementing rules, or official interpretation of any of the foregoing or any replacement, successor or alternative legislation having the same subject matter thereof.
A joint venture with both foreign and Chinese investors. In a CJV, the shareholders may decide to share the dividends or the debts in a manner which is disproportionate from the capital subscription and may decide to arrange the early recovery of the investments of the foreign party in return of the transfer of all the fixed assets to the Chinese party.