Fiduciary Future Conference - Cyprus - 31st October 2012

Fiduciary Future Conference - Cyprus - 31st October 2012
Chinese tax structures and planning alternatives to prepare for Outbound Chinese Investments & China's next export: BILLIONAIRES Fiduciary Future Conference Cyprus st October 2012 Peter Guang Chen

Table of Contents Current state and trend of private wealth growth in China Private wealth planning – PRC tax considerations Private wealth planning – Other PRC considerations PRC Outbound Investment Planning Pre-IPO planning using trusts Who we are and how we can work with you 2

China’s Next Great Export
On 21st September 2012, a visitor to the China Property Investment Show in Beijing, touring booths of foreign property developers 3

Two weeks ago, on 16th October 2012, the Wall Street Journal (“WSJ”), in a story titled “ Cash Leaks Out of China”, reported: “Zheng Nan recently spent €300,000 ($390,000) on a beachfront condo in Cyprus. At 50 years old, he says he is retired from selling telecommunications gear in China for foreign manufacturers. "My plan is to spend winter there because of the pollution in Beijing," he says. "And we will be back for summer.“ “ 4

“According to a Wall Street Journal analysis, in the 12 months through September 2012, about $225 billion flowed out of China, equivalent to about 3% of the nation's economic output last year.” Source: Wall Street Journal, 16th October 2012 5

CURRENT STATE AND TREND OF PRIVATE WEALTH GROWTH IN CHINA
6

Global Billionaires Top 10 Sources of Billionaires Ranking Country
Number of Billionaires 1 United States 413 2 China (including Hong Kong and Taiwan) 176 3 Russia 101 4 India 55 5 Germany 52 6 Turkey 38 7 United Kingdom 32 8 Brazil 30 9 Japan 26 10 Canada 24 The true number of Chinese billionaires is probably much higher, given the likelihood of tycoons who want to hide or under-report the value of their assets (International Business Times, 7 Sept 2011) Source: Forbes 2011 7

Billionaires in China Top 10 Billionaires in China and their Global Rankings Rank Name Net Worth (Billion USD) Age Source 95 Robin Li $9.4 42 Internet 114 Liang Wengen $8.8 54 Manufacturing 169 Zong Qinghou $5.9 66 Beverages 179 Li Li & family $5.7 47 Pharmaceuticals 185 He Xiangjian $5.5 69 Appliances Wu Yajun & family Real estate 200 Hui Ka Yan $5.1 53 208 Zhang Jindong $5 48 Retail Ma Huateng 40 232 Wang Jianlin $4.6 57 29 of the top 50 wealthiest in China are focused on the property sector (International Business Times, 7 Sept 2011) Source: Forbes 8

Growth of Wealth in China
Chinese High Net Worth Individuals 2009 2010 2011 HNWIs with more than USD1.5 million in individual investable assets 2009 2010 2011 HNWIs with more than USD15 million in individual investable assets Source: Private Banking White Paper 2012 (Bank of China and Hurun Research Institute) 9

Top Chinese Companies in Fortune Global 500 In 2012, China has companies in the Fortune Global 500 Top Private Chinese Global 500 Companies Ranking No. of Global 500 Companies United States 133 Japan 68 China 61 73 Country Rank Company Global 500 Rank City Revenues (Million USD) 8 Noble Group 91 Hong Kong 80,732 17 Dongfeng Motor 142 Wuhan 62,911 16 Shanghai Automotive 130 Shanghai 67,255 19 China FAW Group 165 Changchun 57,003 22 Baosteel Group 197 48,916 33 HeBei Iron & Steel Group 258 Shijiazhuang 40,023 10

Overseas Listings 2000 June 2005 As at end of Sept No. of H Shares co. 52 124 (including 2 delisted co.) 171 Based on a recent survey, 165 domestic enterprises listed abroad with over cumulative capital raised of over USD 120 Billion Target markets: Most listed on the HKEx SGX NYSE and NASDAQ RTOs into smaller US exchanges and OTC AIM 11

60% of China’s HNWIs have completed steps to emigrate or are considering emigration Primary reasons for emigration of HNWIs: Children’s education; asset protection; better living environment; flexibility Most desired destinations for emigration: USA Canada Europe Others 12

Private wealth planning – PRC TAX CONSIDERATIONS
13

PRC Taxation on Individuals
Residents are subject to individual income tax on worldwide income; nonresidents are taxed on China sourced income only A resident is defined as a person whose domicile is in China or whose domicile is not in China but lives in China for a full calendar year In general, a Chinese person who obtains foreign citizenship or permanent residency and doesn’t live in China for a full calendar year is considered a nonresident A person is not considered “living in China for a full calendar year” if the person makes: Any single trip overseas longer than 30 days; or Multiple trips overseas the total length of which are more than 90 days 14

Current individual income tax system is income category based, not on a consolidation basis Income is classified into 11 categories Wages and salaries are taxed on a monthly basis Partnership income is taxed on an annual basis Other income such as investment income is taxed on a transaction basis, i.e. taxed each time when the income is received Dividends, interest and capital gains are subject to income tax at 20% Capital gains from public stock and mutual fund investment is currently exempt from income tax Insurance payment is tax exempt 15

No exit tax on changing tax residency No gift tax No estate tax No rules on trust taxation 16

Introduction to outbound investments
Current state of outbound investments Total investment amount now exceeds US$300 billion (including both new investment and dividend reinvestment), which makes China the fifth largest capital export country (after the US, Germany, France and HK) Investments in energy, natural resource and financial industry continue, but investments into other sectors such as manufacturing, logistics, technology, retail, agriculture, luxury brand, tourism, and entertainment grow very fast Players now include many private held companies and investment funds Investment destinations are all over the world, including developed countries 17

Introduction to outbound investments
Choice of legal entity for outbound investments Branch office (not a legal person) No deferral of the taxation in China Profits of a foreign branch can be used to offset with domestic losses, but the losses of a foreign branch cannot be used to offset domestic profits Subsidiary (a legal person) Deferral of Chinese taxation until the distribution of dividends Partnership (not a legal person) People are not very familiar with this type of legal vehicle Investing through an intermediate holding company Typical structure for cross-border investment Tax deferral + exit flexibility Enjoy treaty based lower withholding tax on dividends 18

Common Corporate Tax Issues regarding Cross-border Investments
Foreign incorporated Chinese tax resident A foreign incorporated company is treated as a Chinese tax resident if its effective management is exercised in China The four criteria under Circular 82 The senior management officers reside in China and perform their duties mainly in China The finance decisions and human resource decisions are made or approved by the personnel in China The main assets, accounting books, corporate seals, and the minutes of the board of directors and the shareholders are located in China Half or more than half of the directors or senior officers who have voting power reside in China It is not clear if similar criteria will apply to individual owned foreign entities 19

Consequences of being a Chinese tax resident The dividend/interest/royalty paid to a non-Chinese shareholder is subject to a 10% Chinese withholding tax The sale of the equity interest in such a company is subject to a 10% Chinese capital gains tax (see the case below) 20

Chinese Tax Resident - Beijing Case
2000 S Co. is a leading telecom company in the United Kingdom and T Co. is a red chip company registered and listed in Hong Kong As a strategic investor, S Co. purchased a 2.5% equity interest in T Co. at USD 2 billion in 2000 S Co. purchased more equity in T Co. later and its total interest in T Co. reached 3.2% S Co. sold its equity interest on September 8, 2010 for a gain of USD 3.3 billion The Chinese tax authorities found the sale taxable in China, because T Co. should be considered a Chinese tax resident under Guoshuihan [2009] No. 82 On October 27, 2010, a capital gains tax of RMB 2.2 billion was paid to the Chinese tax authorities S Co. United Kingdom Hong Kong 2.5% T Co. 2010 S Co. United Kingdom Hong Kong 3.2% T Co. 21

Controlled foreign corporations (“CFCs”) Article 45 of the PRC Enterprise Income Tax Law With respect to enterprises that are located in tax jurisdictions where the effective tax rate is significantly lower than that of other tax jurisdictions as provided for in Paragraph 1 of Article 7 and are controlled by Resident Enterprises or controlled by Resident Enterprises and resident individuals, the share of profits attributable to the Resident Enterprises shall be booked as current year taxable income of the Resident Enterprises, if the profit is either not distributed or incompletely distributed absent a reasonable business operation need. Definition of a CFC Is a foreign company 100% owned by a Chinese individual a CFC? How is the effective tax rate defined? 22

Controlled foreign corporations (“CFCs”) Consequences of becoming a CFC Immediately taxable at the Chinese corporate shareholder level Exceptions CFCs located in a country listed on the White List Currently 13 countries Companies that mainly conduct active trade or business CFCs with annual profit of less than RMB 5 million 23

Common tax issues regarding outbound investments
Other anti-avoidance rules Transfer pricing rules in China and the destination country Chinese general anti-avoidance rule Other anti-avoidance rules in the destination countries Thin capitalization rules Anti-treaty shopping rules 24

Foreign tax credit limitation Per-country limitation Only the income and losses from the same country can be offset with each other Three-tier limitation The credit is limited to three tiers below the Chinese parent 25

Per-country limitation Three-tier limitation China China HK HK US 16.5% 35% Lux UK The tax paid in HK and the tax paid in the US cannot be blended US The tax paid in the US cannot be credited 26

Three-tier limitation issue China HK If HK is a partnership or a Chinese tax resident, can this solve the three-tier limitation issue? Lux UK US 27

Tax planning for outbound investments
Preparation before the investment Understand the tax systems in China and the destination country Have a big picture and be forward-looking Leave planning flexibility for future investment Use professional help 28

Effective use of tax treaties Reduce the destination country’s withholding tax on dividends, interest and royalties Reduce the destination country’s capital gains tax on exit Save tax through the avoidance of a permanent establishment Use the tax sparing credit to truly enjoy the tax incentives offered by the destination country Use the mutual agreement procedure to solve the tax disputes with the destination country 29

Holding company planning Investing through a third country holding company E.g. China-Cyprus-Europe, China-Singapore-Indonesia, China-HK-Luxembourg-Canada, etc Using a regional holding company or global holding company to invest E.g. a regional holding company in Cyprus, HK or Singapore Pros and cons of using a tax haven holding company 30

Private wealth planning – Other PRC CONSIDERATIONS
32

PRC Trust Law PRC Trust Law became effective on Oct 1, 2001 and is similar to the trust laws of many other countries However, there is a fundamental difference between a PRC trust and a foreign trust, i.e. whether or not the legal title of the trust assets is transferred to the trustee is not clear under the PRC trust law A PRC trust is mostly used as an asset investment/management tool currently 33

Dealing with an Offshore Trust
Is it recognized under the PRC law? Does the transfer of assets require any PRC government approval (including foreign exchange control)? Offshore assets Onshore assets 34

Other PRC Considerations
Matrimonial property Community property: Property acquired by husband and wife during marriage is jointly owned Other assets are generally personal properties Marital agreements are recognized Wills are recognized Statutory inheritance order in the absence of a will Estate first goes to: Spouse, children and parents If there is no first tier, estate goes to: siblings, grandparents and grandchildren Equal distribution within each tier No probate required Interpretations of the Supreme People’s Court about Several Issues Concerning the Application of the Marriage Law of the People’s Republic of China (III) ( Adopted at the1525th meeting, on July 4, 2011 by the Judicial Committee of the Supreme People’s Court ) Article 7 Where the title of real estate bought by the parents of one party after marriage is registered in the name of the son or daughter of such parents, it is deemed to be donation to their son or daughter and thus to be the personal property of their son or daughter in accordance with the Article 18(3) of the Marriage Law of the People’s Republic of China. Where the purchase of real estate is financed by parents of both parties, and the title of the real property is registered in the name of one party, the property is deemed be property by jointly owned in accordance with their parents’ respective share of contribution unless otherwise agreed by the parties. 35

Tax Issues regarding Trusts
There are no rules on trust taxation No rules on putting assets into the trust No rules on distributing income/assets to the beneficiary No rules on holding assets and income produced by the underlying assets No rules on tax reporting 36

PRE-IPO PLANNING BY USING TRUST
37

Using Trusts Tax Asset Protection Succession Planning
Flexibility in Future Planning Employee Benefit Planning 38

Typical Structure Trustee Beneficiaries Settlor Trust
Holdco 1 Holdco 2 Listco Intermediate Holdco Offshore Onshore Trust Beneficiaries Settlor Public Trustee appointed directors Client nominated independent directors China Co 39

Major Shareholder as director
Tax – Without Trust Holdco 1 Listco Intermediate Holdco China Co Offshore Onshore Major Shareholder Public Major Shareholder as director Distributions to major shareholders or families: PRC individual income tax at 20% Holdco 1: PRC EIT at 25% if management is controlled by PRC resident. 20% Distribution: should be structured to attract no tax 0% Distribution: should be structured to attract no tax 0% Distribution: withholding tax at 5% or 10% (depending on jurisdiction of foreign Holdco) 5%-10% 40

Major Shareholder as director
Tax – Without Trust For every $100 distributed from China, $54 net is received. 100*(1-10%)*(1-25%)*(1-20%) = 54 TAX NET RECEIVED Holdco 1 Listco Intermediate Holdco China Co Offshore Onshore Major Shareholder Public Major Shareholder as director Distribution 41

Tax – With Trust Distribution to major Shareholders or families: NO PRC tax Trust: No PRC tax Trustee Client nominated independent directors Holdco 1 Holdco 2 Listco Intermediate Holdco China Co Offshore Onshore Trust Beneficiaries Settlor Public Trustee appointed directors Holdco 1: NO PRC tax because it is not managed or controlled by a PRC resident Distribution: should be structured to attract no tax 0% Holdco 2: NO PRC tax because it is not managed or controlled by a PRC resident 0% Distribution: should be structured to attract no tax 0% Distribution: should be structured to attract no tax 5%-10% Distribution: withholding tax of 5% or 10% (depending on jurisdiction of foreign Holdco) 42

Tax – With Trust TAX NET RECEIVED Distribution
For every $100 distributed from China, $90 - $95 net is received. Calculated as 100*(1-5% or 10%) Trustee Client nominated independent directors Holdco 1 Holdco 2 Listco Intermediate Holdco China Co Offshore Onshore Trust Beneficiaries Settlor Public Trustee appointed directors TAX NET RECEIVED Distribution 43

Asset Protection Protect family asset against
Trustee Holdco 1 Holdco 2 Listco Intermediate Holdco Offshore Onshore Trust Beneficiaries Settlor Public Trustee appointed directors Client nominated independent directors China Co Protect family asset against Creditors Beneficiaries’ spouses Other related claimants Settlor’s spouse - matrimonial property on transfer? "Ringfence" beneficiaries 44

Succession Unify majority shareholding Unify management and control
Protect control block value Separate ownership from control and economic benefit Provide flexibility in determining management and control Beneficiaries can enjoy economic benefits WITHOUT dilution of value or control Trustee Holdco 1 Holdco 2 Listco Intermediate Holdco Offshore Onshore Trust Beneficiaries Settlor Public Trustee appointed directors Client nominated independent directors China Co 45

Flexibility Can add or remove beneficiaries as determined by settlor or as planned Can adjust to changes in: Family composition Tax residence of beneficiaries Laws Trustee Holdco 1 Holdco 2 Listco Intermediate Holdco Offshore Onshore Trust Beneficiaries Settlor Public Trustee appointed directors Client nominated independent directors China Co 46

Employee Benefit Plans
Trustee Holdco 1 Holdco 2 Listco Intermediate Holdco Offshore Onshore Trust Beneficiaries Settlor Public Trustee appointed directors Client nominated independent directors China Co Allow employees to benefit based on shares WITHOUT having to open brokerage accounts Individual income tax neutral Enterprise income tax neutral Company ensures compliance for tax and withholdings on payments to employees Beneficiaries 47

Disclosure Requirements
Trustee Holdco 1 Holdco 2 Listco Intermediate Holdco Offshore Onshore Trust Beneficiaries Settlor Public Trustee appointed directors Client nominated independent directors China Co Add additional layer for reporting Need coordination Timing of reports Consistency of reports BUT trustee can handle reporting obligations for client 48

Timing Trustee Holdco 1 Holdco 2 Listco Intermediate Holdco Offshore Onshore Trust Beneficiaries Settlor Public Trustee appointed directors Client nominated independent directors China Co Need to put personal planning structure in place in coordination with pre-IPO reorganization for listing If NOT done BEFORE IPO, the transaction will be subject to lock-up, general offer and additional disclosure requirements 49

Examples of Offshore Listings with Trusts
SOHO China Limited (HK Stock Code: 410) SITC International Holdings Company Ltd. (HK Stock Code: 1308) Goodbaby Holdings Ltd. (HK Stock Code: 1086) Trony Solar Holdings Company Ltd. (HK Stock Code: 2468) Sateri Holdings Ltd. (HK Stock Code: 1768) China ZhengTong Auto Services Holdings Limited (HK Stock Code: 1728) Greatview Aseptic Packaging Co. Ltd. (HK Stock Code: 468) Sihuan Pharmaceutical Holdings Group Ltd. (HK Stock Code: 460) International Taifeng Holdings Ltd. (HK Stock Code: 873) Costin New Materials Group Ltd. (HK Stock Code: 2228) E-Commerce China DangDang (NYSE Stock Symbol: DANG) Soufun Holdings Limited (NYSE Stock Symbol: SFUN) JinkoSolar Holding Co. Ltd (NYSE Stock Symbol: JKS) Camelot Information Systems Inc. (NYSE Stock Symbol: CIS) China Lodging Group Limited (NASDAQ Stock Symbol: HTHT) Shanda Interactive Entertainment Ltd (NASDAQ Stock Symbol: SNDA) Vimicro International Corporation (NASDAQ Stock Symbol: VIMC) 50

Who We Are Peter Guang Chen HONG KONG OFFICE +852 2298.7637
AREAS OF PRACTICE Peter’s practice covers all tax aspects of cross-border investments and transactions, investment structuring and restructuring, M&A, financing, pre-IPO restructuring, transfer pricing, and tax planning for private individuals clients. BACKGROUND Peter is both a certified public accountant and an attorney with more than 25 years of experience. His has advised China , Hong Kong and US corporations on their inbound and outbound transactions; China and international tax issues, investment structuring, regulatory, and business issues; mergers , acquisitions; and the reorganizations of multinationals in China and the Asia Pacific region. He has represented companies and individuals to resolve tax disputes with tax authorities in China and the US. Previously, Peter was a with a major economic consulting firm and also was a tax partner at Deloitte, where he was responsible for the China Desk in NYC, and served as China leader of the Deloitte International Core of Excellence. He is fluent in English and Chinese (Mandarin, Shanghai, and Cantonese dialects). . HONG KONG OFFICE 51

Who We Are Clifford S.M. Ng HONG KONG OFFICE +852 2298 7603
AREAS OF PRACTICE Clifford is a partner in Zhong Lun’s Hong Kong office. He has been working with some of Asia's leading business families for over 20 years. Clifford started his practice in Canada and returned to Hong Kong in He provides strategic advice to private clients including major shareholders of listed companies to address asset preservation, corporate, securities, succession and tax issues. Clifford is recognized by Chambers as one of the leading private client lawyers in China. BACKGROUND Clifford is a solicitor in Hong Kong, England and Wales and a barrister and solicitor in British Columbia, Canada. Clifford graduated with a Bachelor of Arts degree in Economics from the University of British Columbia. He obtained his LL.B from Dalhousie University, Canada. Clifford articled and practiced with one of Canada's leading firms before moving to that firm's Hong Kong office in He practiced with a global firm in Hong Kong from 2003 leading their Asia offices until 2011 when he joined Zhong Lun. HONG KONG OFFICE 52

Who We Are Yongjun Peter Ni SHANGHAI OFFICE +8621 6061 3568
AREAS OF PRACTICE Peter’s practice covers all tax aspects of cross-border investments and transactions, with a focus on market entry and exit strategies, investment structuring and restructuring, M&A, financing, pre-IPO restructuring, import and export, transfer pricing, tax-efficient supply chain management, tax dispute resolution, executive compensation, and private wealth management. Peter is recognized by Chambers as one of the leading tax lawyers in China. BACKGROUND Peter is the head of Zhong Lun Law Firm’s tax practice. Before joining Zhong Lun, he led White & Case’s Greater China tax practice. Prior to that, he led the International Tax Practice of Ernst & Young China. Peter has more than 15 years of international tax experience, including nine years in the US. Trained as a lawyer, he is able to provide tax advice in the proper legal context. Peter has been ranked as a Leading Individual in China Tax by many international directories. Peter graduated from Harvard Law School, New York University School of Law and Fudan University in China. He is qualified to practice law in both the US and China. SHANGHAI OFFICE 53

Zhong Lun Law Firm Zhong Lun was named by Chambers Asia as
Zhong Lun was founded in 1993 as one of the first private partnership firms in China. Since then, Zhong Lun has emerged as one of China’s leading law firms with approximately 800 lawyers in offices in Beijing, Shanghai, Shenzhen, Guangzhou, Wuhan, Chengdu, Hong Kong and Tokyo. Zhong Lun was named by Chambers Asia as National Law Firm of the Year for China for 2011 Major Practices Areas include: Banking and Finance Bankruptcy and Corporate Reorganization Competition/Antitrust Corporate Finance and Capital Markets Dispute Resolution Employment Foreign Direct Investment International Trade and WTO Intellectual Property Private Equity and Venture Capital Mergers and Acquisitions Technology, Media and Telecommunications Real Estate and Construction Securities Structured Finance and Securitization Tax Private Client 54

Zhong Lun Law Firm International Financial Law Review: The Guide to the World’s Leading Financial Law Firms 2012 Tier One Firm in capital markets, M&A and private equity, Tier Two Firm in banking and project financing Top rankings from Chambers and Partners “Winner, International Trade Law Firm” (Chambers China Awards 2011) “Winner, Real Estate Law Firm” (Chambers China Awards 2010, 2011) “China Law Firm of the Year 2011 (National)” at the Chambers Asia Pacific Awards 2011. Banking and finance (band 1) Capital markets: securitization and structured finance (band 1) Competition/antitrust (band 1) Construction (band 1) Corporate/M & A (band 1) International trade (band 1) Private equity (band 1) Real estate (band 1) Restructuring & insolvency (band 1) IT, telecommunications, media and entertainment (band 1) Capital markets: debt securities (band 2) Dispute resolution (band 2) Employment (band 2) Intellectual property (band 3) China Law & Practice Awards 2011 China Real Estate & Construction Team of the Year Real Estate & Construction Deal of the Year (Shanghai Disney Project) Project Finance Deal of the Year (Gansu Guazhou Wind Power Project) Asia Law and Practice Leading Lawyers ( ) A number of Zhong Lun partners were rated Leading Lawyers for several consecutive years Excellent results in ChiNext Listings As at 31 October 2010, Zhong Lun acted for 13 enterprises in applying for listing on the ChiNext (the growth enterprise market of Shenzhen Stock Exchange), 12 of which have been approved by the China Securities Regulatory Commission (CSRC), which earned Zhong Lun a No.2 position in terms of market share among law firms. According to ChiNext statistics 2010, Zhong Lun also has the highest rate of ChiNext listing application approvals. Pacific Business Press (PBP) China Best Real Estate Law Firm Award One of the Best Real Estate Law Firms of China”, Asian-Counsel Firms of the Year 2009 – Representing Corporate Asia Survey Practical Law Company (PLC) – Highest Ranking in the China Region Zhong Lun’s real estate practice was awarded the highest ranking in the China region for the year 2009/2010. Zhong Lun was the only PRC-based law firm among the 4 recommended firms. 55

Our Tax Practice and Private Client Practice
Our Private Client Practice As the private sector grows within the Chinese economy, the planning for private wealth will become more important for entrepreneurs and business people in China. Zhong Lun is unique among domestic firms with a dedicated private client practice focused on the issues faced by high net worth clients. We advise clients on asset protection, succession planning, philanthropy, business continuation and governance, tax and other issues. Through our Hong Kong office, we also advise clients on compliance regimes for securities regulations and tax and other laws applicable to listings overseas. Our professionals have extensive experience working with business people with family members, businesses and assets in different countries under different legal regimes. We work with leading international financial institutions and advisors around the world to ensure families achieve their business and family objectives. Our Taxation Practice Zhong Lun is one of the very few law firms in China that offer comprehensive tax services with a focus on international tax. Our tax lawyers have extensive experience on cross border as well as domestic transactions in China and overseas. Zhong Lun’s tax services cover all the areas related to cross-border investments and transactions, with a focus on: Tax planning for private clients and corporate executives Investment structuring Restructuring and M&As, including pre-IPO restructuring Financing structuring Tax efficient supply chain management planning Tax advisory services on day to day company operations Tax planning for import and export Transfer pricing Tax dispute resolution 56

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Fiduciary Future Conference - Cyprus - 31st October 2012

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