龍光集團(03380.HK)于2021年1月14日發布公告，披露公司作為開曼群島注冊成立的控股公司，境外投資者轉讓公司股份，或觸發非居民企業間接轉讓境內股權，該筆交易將被扣繳10%預提所得稅。“if a non-resident enterprise transfers its shares in a foreign enterprise which holds shares in a PRC resident enterprise, this transfer may be subject to CIT at the rate of 10%, provided, if such non-resident enterprise is deemed by the relevant PRC authorities to have indirectly transferred its shares in the PRC resident enterprises through an arrangement without reasonable commercial purposes that results in the abuse of organizational structure.”
大力稅手注：龍光集團系注冊于開曼的BVI公司，本次擬發行300,000,000美元2028年到期年息4.5%的優先票據。
《龍光集團有限公司 - 300,000,000美元二零二八年到期年息4.5%的優先票據(「票據」,》【2021-01-14】詳細披露如下：
According to the Announcement of the State Administration of Taxation on Issues Concerningthe Special Tax Treatment Applicable to Equity Transfer by Non-resident Enterprises (國家稅務總局關于非居民企業股權轉讓適用特殊性稅務處理有關問題的公告) issued by the State Administration of Taxation in December 2013 and was amended on June 1, 2015 and June 15, 2018, and the Announcement on the Several Issues Relating to Enterprise Income Tax on Non-resident Enterprises’ Indirect Asset Transfer (國家稅務總局關于非居民企業間接轉讓財產企業所得稅若干問題的公告) issued by the State Administration of Taxation in February 2015 and became partly invalid from December 1, 2017 and December 29, 2017, if a non-resident enterprise transfers its shares in a foreign enterprise which holds shares in a PRC resident enterprise, this transfer may be subject to CIT at the rate of 10%, provided, if such non-resident enterprise is deemed by the relevant PRC authorities to have indirectly transferred its shares in the PRC resident enterprises through an arrangement without reasonable commercial purposes that results in the abuse of organizational structure.
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