企业合并分立案例例子的中国税务分析解析(英文)资料.pdfVIP

SC Group PRC Tax Analysis on the Proposed MA Project 23 November, 2010 Content I. Our Understanding II. PRC Tax Implications 1) Merger 2) After the merger • Option I – Spin-off • Option II – Transfer assets to CM III. Other Consideration IV. Appendix 2 I. Our Understanding SC Group is mainly engaged in manufacturing business and has several PRC entities in China. Currently, the Management would like to restructure its holding structure within the Group. The curr