Case detail
Chongqing Yuhuan indirect transfer case (representative)
SAT Public Notice 7 (2015)
Court
State Taxation Administration
Date
2015-02-03
Outcome
for-government
Holding
SAT Public Notice 7 replaced and updated Notice 698 to provide more detailed rules for taxing indirect transfers, including safe harbors and reasonable-commercial-purpose tests.
Facts
Following a series of indirect-transfer cases, the SAT issued Public Notice 7 to provide modernized rules.
Reasoning
The notice expanded scope, clarified safe harbors for genuine reorganizations and public-market transactions, and provided detail on reasonable-commercial-purpose analysis. Public Notice 7 remains the principal Chinese administrative guidance on indirect transfers.
Case metadata
Official opinion
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Primary sources
- State Taxation Administration of ChinaVerified 2026-05-20
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