国家税务总局发布《关于依据实际管理机构标准实施居民企业认定有关问题的公告》

The State Administration of Taxation Releases an Announcement concerning Relevant Issues of Resident Enterprise Identification in Accordance with the Place of Effective Management Standard

2008年企业所得税法实施后，有关股息所得税的政策发生了变化，即对境外投资者从我国境内取得的股息、红利所得恢复征收所得税。由此，境外红筹中资控股企业面临股息重复征税的问题。

Since the implementation of the Enterprise Income Tax Law in 2008, the dividends income tax policy has been changed accordingly, i.e., the dividends received from China by foreign investors are no longer exempt from the enterprise income tax. Therefore, the dividends derived by a foreign company established by a Chinese enterprise are at risk of double taxation.