This English translation is for reference only. The Chinese version shall prevail in case of any inconsistencies.
Notice by the Department of Finance of Guangdong Province and the Guangdong Provincial Tax Service of the State Taxation Administration on Forwarding the Notice of the Ministry of Finance and the State Taxation Administration on Preferential Enterprise Income Tax Policies for the Guangdong-Macao In-Depth Cooperation Zone in Hengqin
(No. 17 [2022] of the Department of Finance of Guangdong Province and Guangdong Provincial Tax Service of the State Taxation Administration)
Finance Bureau of Guangdong-Macao In-Depth Cooperation Zone in Hengqin and Tax Administration of the State Taxation Administration in Guangdong-Macao In-Depth Cooperation Zone in Hengqin:
The Notice by the Ministry of Finance and the State Taxation Administration on Preferential Enterprise Income Tax Policies for the Guangdong-Macao In-Depth Cooperation Zone in Hengqin (No. 19 [2022] of the Ministry of Finance and the State Taxation Administration) is hereby forwarded to you, along with the following opinions, for your implementation.
I. Enhance coordination and cooperation. The finance and taxation authorities in the Hengqin Guangdong-Macao In-Depth Cooperation Zone (hereinafter referred to as the “Cooperation Zone”) shall proactively leverage their expertise to: establish a dedicated task force, develop a comprehensive work plan, and create a coordination mechanism with relevant industry regulators. These efforts will ensure effective implementation of preferential enterprise income tax policies within the Cooperation Zone.
II. Refine implementation measures. The finance and taxation authorities in the Cooperation Zone shall lead a collaborative effort with relevant bureaus, including legal affairs, economic development, and commercial services, to conduct in-depth study on specific policy measures, streamline tax collection and management procedures, develop clear implementation guidelines and work instructions for defining primary and substantial business operations, strengthen personnel training programs, and implement robust publicity and policy interpretation initiatives. This coordinated approach will ensure that businesses in the Cooperation Zone can promptly benefit from these preferential policies.
III. Strengthen risk prevention and management. Relevant parties and units shall implement risk prevention measures. This includes: establishing comprehensive pre-event, in-event, and post-event management processes; enforcing policies in strict accordance with the preferential catalogue; and strengthening the regulation and oversight of enterprises engaged in substantial business operations. The Finance, Economic Development, Commercial Services, and other relevant bureaus shall intensify their scrutiny of substantial business operations. Any violations of laws and regulations, including fraudulent applications, will be subject to strict investigation and penalties as per established regulations. Any policy implementation issues that cannot be resolved at the local level shall be submitted to the appropriate higher authorities without delay.
IV. Conduct implementation evaluation. Relevant parties and units shall conduct timely evaluations and summaries of policy implementation and submit a written report on policy implementation and evaluation results to the Department of Finance of Guangdong Province and the Guangdong Provincial Tax Service Administration within 30 working days after the annual enterprise income tax filing deadline.
Annex: Notice by the Ministry of Finance and the State Taxation Administration on Preferential Enterprise Income Tax Policies for the Guangdong-Macao In-Depth Cooperation Zone in Hengqin
Department of Finance of Guangdong Province, Guangdong Provincial Tax Service of the State Taxation Administration
May 25, 2022
Notice by the Ministry of Finance and the State Taxation Administration on Preferential Enterprise Income Tax Policies in the Guangdong-Macao In-Depth Cooperation Zone in Hengqin
(No. 19 [2022] of the Ministry of Finance and the State Taxation Administration)
Department of Finance of Guangdong Province, Guangdong Provincial Tax Service of the State Taxation Administration:
To support the construction of Guangdong-Macao In-Depth Cooperation Zone in Hengqin (hereinafter referred to as the “Cooperation Zone”), preferential enterprise income tax policies are hereby notified to you:
I. The enterprise income tax on eligible enterprises established in the Guangdong-Macao In-Depth Cooperation Zone in Hengqin shall be levied at a reduced rate of 15%.
Enterprises eligible for the preferential policy under this article shall meet the following conditions:
1. The enterprise’s main business shall consist of the industrial projects specified in the Catalogue for Preferential Enterprise Income Tax in the Guangdong-Macao In-Depth Cooperation Zone in Hengqin (2021 Edition) (hereinafter referred to as the “Catalogue”, see Annex), and its main business revenue shall account for 60% or more of its total revenue. The total revenue shall be calculated in accordance with Article 6 of the Enterprise Income Tax Law of the People’s Republic of China.
2. The enterprise must engage in substantive operations. This means that the enterprise’s actual management institution must be located in the Cooperation Zone and exercise comprehensive management and control over its production and operations, personnel, accounts, and assets. Enterprises that do not meet the substantive operations requirements shall not be eligible for the preferential treatment.
For enterprises with headquarters located in the Cooperation Zone, the 15% tax rate applies only to the income of their headquarters and branch offices within the Cooperation Zone that meet the stipulated conditions. For enterprises with headquarters outside the Cooperation Zone, the 15% tax rate applies only to the income of their branch offices within the Cooperation Zone that meet the stipulated conditions. The specific tax collection and administration measures shall follow the regulations of the State Taxation Administration.
II. Enterprises in the tourism, modern services, and high-tech industries established in the Cooperation Zone shall be exempt from enterprise income tax on income from new foreign direct investments.
The income from new foreign direct investments referred to in this article shall meet the following conditions:
1. It includes either business profits from newly established branch offices outside the Chinese mainland or dividend income from subsidiaries outside the Chinese mainland where the enterprise holds 20% or more of the shares, corresponding to the new foreign direct investments.
2. The statutory enterprise income tax rate in the country or region where the investment is made must be at least 5%.
The tourism, modern services, and high-tech industries referred to in this article shall be defined according to the categories specified in the Catalogue.
III. For enterprises established in the Cooperation Zone, newly purchased (including self-built or self-developed) fixed assets or intangible assets with a unit value of up to 5 million yuan may be fully expensed in the current period and deducted when calculating taxable income, without needing to depreciate or amortize them over several years. For assets with a unit value exceeding 5 million yuan, enterprises may opt for a shortened depreciation or amortization period or use accelerated depreciation or amortization methods.
In this article, “fixed assets” refers to assets other than buildings and structures.
IV. The scope of the Guangdong-Macao In-Depth Cooperation Zone in Hengqin specified in this Notice shall follow the Master Plan for the Construction of Guangdong-Macao In-Depth Cooperation Zone in Hengqin, issued by the Central Committee of the Communist Party of China and the State Council in 2021.
V. If the tax authorities find it difficult to determine whether an enterprise’s main business falls within the scope of the Catalogue, they may request an opinion from the relevant administrative department of the People’s Government of Guangdong Province or the subordinate authority authorized by it.
VI. This Notice shall come into effect on January 1, 2021.
Annex: Preferential Catalogue of Enterprise Income Tax in Guangdong-Macao In-Depth Cooperation Zone in Hengqin (2021 edition)
Ministry of Finance of the People’s Republic of China
State Taxation Administration
May 25, 2022
Annex
Catalogue for Preferential Enterprise Income Tax in Guangdong-Macao In-Depth Cooperation Zone in Hengqin
(2021 edition)
I. High-tech Industries
1. Integrated circuit (IC) design, advanced IC packaging and testing, research and development (hereinafter referred to as “R&D”) and manufacturing of specialized processes, R&D and manufacturing of semiconductor equipment and key materials, IC chip design platforms (EDA tools), R&D of related software, supporting IP libraries
2. Artificial intelligence products, ergonomics, system simulation design, biochips and related data acquisition, processing technology development, and test equipment manufacturing
3. R&D and production of new functional polymer materials, bio-based materials, bio-based synthetic polymer materials, natural biopolymer materials, bio-based platform compounds, bionic intelligence and metamaterials, low-dimensional materials and nanomaterials, high-performance fibers, new electronic materials and electronic chemicals, advanced metal materials, new composite materials, superconducting materials, additive manufacturing materials, and new energy materials
4. R&D and manufacturing of advanced manufacturing technologies in microelectronics, electronic components, computers, information, biology, new materials, environmental protection, machinery and equipment, automobiles, and shipbuilding
5. R&D of next-generation Internet technologies based on IPv6, and the development and manufacturing of system equipment, terminal equipment, testing equipment, software, and chips
6. R&D and manufacturing of cell phones, base stations, core network equipment, and network testing equipment for the fifth generation and subsequent mobile communication systems
7. R&D of industrial Internet, Internet of Things, autonomous driving technologies, and information technology for smart consumer devices
8. Professional scientific and technological services across various industries, including aerospace, biomedicine, marine, new energy, new materials, and low-carbon environmental protection
9. R&D of intelligent vehicles, new energy vehicles and key components
10. Development of intelligent ships and related intelligent systems and equipment
11. R&D of supporting power grids and charging station technologies and equipment for new energy vehicles
12. Development and production of energy internet technologies and equipment, such as complementary technologies for traditional and new energy power generation, energy routing, and energy trading
13. R&D of smart energy systems and distributed energy
14. Development of large-capacity electric energy storage technologies, and R&D of distributed power supply and grid-connection technologies (including microgrids)
15. Development of solar photovoltaic power generation technology, thermal power generation technology, and high-temperature utilization technology, and the design and manufacturing of integrated solar building components and equipment
16. Development of design technologies for wind turbines with a capacity of 5 MW or above and supporting technologies for wind farms
17. R&D of technologies for constructing critical network devices, application systems for industry and enterprise informatization, sensor network nodes, software and system technologies, and big data technologies
18. Development and manufacturing of cybersecurity products, data security products, and specialized network monitoring equipment
19. R&D and manufacturing of fundamental software and hardware, such as general-purpose or high-end general-purpose processors, memory, and operating systems, as well as their related testing and verification tools
20. Development and manufacturing of value-added service application systems based on the integration of telecommunications, broadcasting, and computer networks
21. R&D of network information service technologies
22. Internet information services and platform development and operation
23. R&D of multi-dimensional and stereoscopic display and printing technologies
24. Development of supporting public service platform technologies for industry clusters
25. Development of optical transmission, small access device, wireless access, mobile communication, quantum communication, and optical communication technologies
26. Development of soft switching and VoIP systems, business operation support systems, and value-added service application systems for telecommunications networks
27. Development of digital audio-video, digital broadcasting and transmission, integrated management systems for broadcasting networks and network operation, IPTV, and high-end personal media information service platforms
28. R&D and manufacturing of digital multi-function radars specialized supporting equipment and components.
29. R&D of air traffic control, next-generation civil aviation operation support, satellite communication, and satellite navigation application systems
30. Development and production of aviation and aerospace technology applications, system software and hardware products, and terminal products
31. R&D and manufacturing of unmanned ships and drones
32. R&D and production of gene sequencing, stem cells, functional proteins, life health technologies, and other emerging science and technology products
33. Development and services for marine medicine and biochemical product technologies
34. Development of marine biomass energy and ocean energy (tidal energy, tidal current energy, wave energy, etc.) technologies
35. R&D of oceanographic engineering equipment and its application technologies, smart ocean and marine information service technologies
36. Development of breeding, cultivation, and selective breeding technologies for rare animals and plants
37. Development of food safety technologies, biological catalysis, reaction, and separation technologies
38. Development of rapid drug safety testing technologies and food and drug instruments and equipment
39. R&D and services for carbon capture, utilization, and storage (CCUS) technologies
40. Application of data asset ownership confirmation, registration, and trading technologies and methods
41. Development and manufacturing of clean production, comprehensive resource utilization, and mobile new energy technologies and products
42. R&D of intelligent construction technologies for green building materials, prefabricated buildings, steel structure houses, etc.
43. Development of building information modeling (BIM) technologies
44. Development and production of key urban ecosystem technologies, safe drinking water and advanced water purification equipment technologies
45. Energy system management, optimization and control technologies, with a particular focus on the development of application technologies used in urban building heating balance and energy conservation, green buildings, urban intelligent lighting, and green lighting systems
46. Development of optical monitoring and other technologies for environmental safety monitoring, early warning, and emergency response
47. Development and production of electric power safety technologies, new lightning overvoltage protection materials, technologies, and equipment
48. Transformation and upgrading of installation technologies for electrical, piping, and other equipment
49. Development and application of systems for domestic garbage treatment, centralized utilization and disposal of hazardous waste, and centralized treatment of urban medical waste
50. Production of urban high-precision navigation, remote sensing images, and 3D data, and development of related key technologies
51. Development of city information modeling (CIM) technologies based on big data, the Internet of Things, GIS, and other related technologies
52. Development of intercity and intra-city (suburban) railway, digital railway and intelligent transportation technologies
53. Development of passenger dedicated line (PDL) and high-speed railway system technologies
54. Development of rapid detection and testing technologies for dangerous items, including radioactive substances, drugs and other contraband, and nuclear and biochemical terrorist sources
55. Development of technologies for important infrastructure and social and public security, and for prevention and protection against meteorological and biological disasters
56. Development of key technologies for intelligent unmanned emergency rescue in major accidents and disasters
II. Science, Education and R&D Industries
57. Branches of domestic and overseas scientific research institutions, and new R&D institutions
58. Operation of national engineering and technology research centers, national industry innovation centers, national agricultural high-tech industry demonstration projects, national agricultural science and technology parks, traditional Chinese medicine (TCM) science and technology experimental centers, state-recognized enterprise technology centers, national laboratories and state key laboratories, national major scientific and technological infrastructure, high-tech entrepreneurial service centers, green technology innovation base platforms, new product development and design centers, science and education infrastructure, comprehensive public service platforms for industry clusters, pilot-scale experiment bases, and other experiment bases
59. Higher education, international education, vocational skills training, sports schools and training, and culture and art training
60. Development of technologies for general, industry-specific application, embedded, and supporting software
61. Open-source software communities
62. R&D of new-mechanism computer systems, including quantum and brain-like computing
63. Development of bioengineering and biomedical engineering technologies
III. Traditional Chinese Medicine (TCM) Industries
64. Development and production of artificial propagation technologies for endangered and rare medicinal plants and animals, as well as their substitutes; application of advanced agricultural technologies in the standardized planting and breeding of traditional Chinese medicinal materials; development and application of new technologies for the extraction, purification, and quality control of active ingredients in TCMs; development and application of modern formulation techniques, production process control technologies, and equipment for TCMs; development and application of innovative technologies for TCMs prepared in ready-to-use forms; secondary development and production of Chinese patent medicines
65. Establishment of industrialization standards for the R&D, processing, production, testing, and certification of TCMs, health care products, Chinese patent medicines, TCM food, homology of medicine and food, classical and famous Chinese medicine prescriptions, and formula food for special medical purposes
66. TCM research institutes and laboratories, and studios of famous and senior TCM physicians
67. Intermediary institutions for trade in TCM services, transformation of achievements in TCM scientific and technological services, and other related services
IV. Pharmaceutical and Healthcare Industries
68. Development and production of new medicines with independent intellectual property rights (IPR)
69. Development and production of natural medicines
70. Pioneering development and production of generic medicines that address China’s needs for the prevention and treatment of major and frequently occurring diseases
71. Development and production of new drug formulations, new adjuvant materials, children’s medications, and drugs in short supply
72. Development and application of technologies in medicine production, including membrane separation, supercritical extraction, novel crystallization, chiral synthesis, enzymatic synthesis, continuous reaction, system control, etc.
73. Development and application of energy-saving and emission-reducing technologies in active pharmaceutical ingredient (API) production and new pharmaceutical preparation technologies
74. Development and production of new pharmaceutical packaging materials and related technologies
75. Development and production of new pharmaceutical packaging materials and related technologies
76. R&D and production of cutting-edge life sciences technologies and products, biological products, high-end medical equipment, and high-end medical device technologies and products
77. Pharmaceutical R&D centers
78. Operation of medical research institutions, including advanced technology clinical medical research centers, clinical trial institutions, key laboratories, etc.
79. Operation of big health industries, including third-party medical testing, hygiene testing, health management, rehabilitation nursing, psychological counseling, etc., as well as the evaluation of medical quality, health training, and medical service capabilities
80. Operation of international academic exchange platforms in the medical and health field, international medical organizations, international conferences and exhibitions in the medical and health field, and medical museums
81. Development of medicinal animal and plant resources, and the operation of GAP production bases for traditional Chinese medicinal materials, trading platforms for green authentic medicinal materials and special health products, national pilot demonstration bases for the transfer and transformation of pharmaceutical achievements, and service platforms and trading centers for the transfer and transformation of pharmaceutical technology achievements
82. Development and production of new medical diagnostic instruments and equipment, minimally invasive surgery and interventional therapy devices, medical first-aid and mobile medical equipment, rehabilitation engineering devices, home medical instruments, new medical materials, artificial organs, and key components; development and application of digital medical imaging products and medical information technologies
83. R&D of new medical diagnostic reagents, as well as testing reagents and instruments for major epidemics and newly discovered infectious diseases
84. R&D and manufacturing of biomedical metal materials, biomedical polymer materials, biomedical inorganic non-metallic materials or bioceramics, biomedical composite materials, and biomedical derived materials
85. R&D and production of AIDS vaccines, hepatitis C vaccines, new vaccines for cervical cancer, malaria, and hand-foot-and-mouth disease, and vaccines for the prevention of major epidemics
86. R&D and production of new anticancer drugs, new cardiovascular and cerebrovascular drugs, new nervous system drugs, antibody drugs, gene therapy drugs, cell therapy drugs, recombinant protein drugs, nucleic acid drugs, marine drugs, etc.
87. Operation of medical institutions and healthcare facilities
88. R&D of internet hospitals, “Internet +” healthcare services, and medical big data technology
V. Other Macao Brand Industries
89. Design and processing of diamonds, jewelry, and gold and silver metal jewelry, and the operation of diamond and gemstone trading centers
90. Design and production of food, beverages, condiments, and healthcare products approved and registered in Macao and produced in the Cooperation Zone
91. R&D and production of cosmetics (with mercury content not exceeding 0.0001%)
VI. Cultural, Convention and Exhibition, and Trade Industries
92. R&D, design, processing, and production of folk culture products and arts and crafts
93. Operation of cinema chains, cultural and artistic enterprises, press and publication, mass culture, and science popularization facilities
94. Creative design and services, including visual communication design, architecture, landscape and interior design, industrial design, fashion design, and high-end arts and crafts design
95. International conferences, brand exhibitions, professional exhibitions, artwork trading, and related services
96. Operation of international convention and exhibition venues
97. Trade brokerage, agency, and services between the mainland, Macao, and Portuguese-speaking countries
98. Operation of brand experience stores, brand outlet shopping centers, chain convenience stores, theme malls, supermarkets, as well as comprehensive experience shopping centers, including high-quality consumer goods trading centers
VII. Tourism
99. Operation of playgrounds, aquariums, theme parks, film and television shooting bases, exhibition halls, and museums
100. Operation of marine sports, low-altitude flights over sea areas, cruise tourism, yacht tourism, and island tourism
101. Cultural and creative tourism, health and medical tourism, exhibition tourism, immersive tourism performances, film, television, and music festivals, folk activities, and cultural heritage preservation and management
102. Cultural and sports activities and the operation of related venues 103. Operation of tourism e-commerce
104. Operation of tourism companies specializing in Guangdong-Hong Kong-Macao tourism
105. Branding and chain operation of distinctive cultural, tourism, and catering businesses
106. Operation of TCM health tourism bases, forest health care bases, forest experience bases, national forest trails, self-driving campsites (including RVs), business campsites, agricultural and forest tourist attractions, hotels, distinctive small and medium-sized family-run hotels, inns, passenger terminals, and yacht marinas
107. R&D and manufacturing of yachts
108. R&D and operation of high-speed waterway passenger transport, passenger intermodal transport facilities and equipment, ticketing integration, and intermodal products
VIII. Modern Service Industries
109. Development of industry (enterprise) management and informatization solutions
110. Development of digital technologies, high-speed computing technologies, and cultural information resource sharing technologies
111. R&D of products and services related to information security technology
112. Information technology outsourcing, business process outsourcing, knowledge process outsourcing, and other technologically advanced services
113. Technology and product development services for digital economy-related industries, including cloud computing, edge computing, the Internet of Things, blockchain, high-performance computing, big data, new media, etc.
114. Science and technology information exchange, literature information retrieval, technical consultation, technology incubation, assessment of technological achievements, transfer and transformation services for scientific and technological achievements, science and technology attestation, and other related services
115. R&D of animation and related derivative products
116. Cultural and creative design services, and cultural information resource development and creation services
117. R&D of digital products, including digital music, mobile media, digital media, digital learning, digital film and television, digital publishing and archiving, content software, etc.
118. Construction of broadband communication infrastructure and related services
119. Third-party logistics and management
120. Development and construction of public logistics information platforms
121. Operation of express delivery service outlets, stores, and related facilities
122. Supply chain management, services, technological innovation, and application
123. Cross-border database services
124. Development and operation of platforms for the sharing economy and platform economy
125. Construction of online service platforms for smart sports and e-sports
126. Regional headquarters of multinational companies and Macao-funded production and operation management centers established in the Cooperation Zone
127. Construction of urban gas, cooling, water supply, and drainage pipeline networks, and construction and operation of urban underground pipeline networks
128. Operation of urban roads and intelligent transportation systems
129. Operation of intensive parking facilities, including parking buildings, underground parking lots, and mechanical multilevel parking garages, etc., and the operation of electric vehicle charging facilities at parking lots
130. Development of key technological products for sponge city construction
131. Development and construction of information systems for automobile passenger and freight transportation stations, urban bus stations, urban public transportation, and taxi service dispatch
132. Credit investigation and rating, credit reporting, and other credit services
133. Human resources, human capital services, and other professional services
134. Intellectual property rights (IPR) agency, transfer, registration, identification, retrieval, analysis, assessment, operation, certification, consulting, and other related services
135. Professional comprehensive services provided by Contract Research Organizations (CROs), Contract Manufacturing Organizations (CMOs), and Contract Development and Manufacturing Organizations (CDMOs)
136. Professional services, including management consulting, urban planning, project management, energy conservation and environmental protection, as well as inspection, testing, certification, etc.
137. Legal, accounting, taxation, energy saving, and environmental protection consulting and services
138. Standardization and informatization of operational management in service industries, including tourism, commerce, hotels, etc.
139. Asset appraisal, calibration, testing, inspection, and other services
140. Elderly care services, childcare services, and housekeeping services
141. Operation of international aircraft, aerospace and aviation materials trading markets, and air cargo services
142. Operation of the China-Portugal International Trade Center and the international hub port of digital trade
143. Cross-border e-commerce
144. Operation of auction companies
IX. Modern Financial Industry
145. Construction of a two-way open service system for cross-border investment and financing
146. Microloan services for agriculture, rural areas, farmers, small low-profit enterprises, micro and small business owners, and individual industrial and commercial households
147. R&D, application, and service provision of fintech products by institutions established with the approval of and regulated by financial management authorities
148. Construction of green finance service systems
149. Operation of trading venues for traditional Chinese medicinal materials, intellectual property rights (IPR), bulk commodities, and financial assets
150. Construction of the RMB cross-border settlement system