The Ministry of Finance (MOF) and the State Administration of Taxation (SAT) published a Notice, "Certain issues regarding the enterprise income tax treatment of enterprise reorganization", on 7 May 2009 (Notice [2009] No.59) by reference to Art. 20 of the Enterprise Income Tax Law of the People's Republic of China and Art. 75 of the Implementation Regulations of the Enterprise Income Tax Law of the People's Republic of China. The Notice, which applies retroactively from 1 January 2008, is summarized below. Definitions A "corporate reorganization" refers to a transaction altering the legal or economic structure of an enterprise, which is...