New Chinese tax incentives for innovation and private pension provision

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

New Chinese tax incentives for innovation and private pension provision

Sponsored by

sponsored-firms-kpmg.png
intl-updates

Following on from the annual meeting of China's Parliament, the National People's Congress (NPC), in early March, the Chinese government has been implementing a string of tax reform measures, the most recent of which was the VAT rate reductions.

At an executive meeting of China's State Council on April 25 2018, Premier Li Keqiang outlined seven further tax reduction measures, this time relating to the corporate income tax (CIT) treatment of innovation activities.

  • Under China's research and development (R&D) super deduction incentive, a 150% deduction (i.e. a 50% bonus deduction) is available for eligible R&D expenses. This rises to 175% for science and technology small and medium enterprises (SMEs). However, under rules issued in 2015, Chinese enterprises outsourcing research work to domestic service providers have faced an 80% deduction cap, which applies to both the expense itself and the super deduction bonus (i.e. a payment of RMB 100 ($16), which would otherwise bring with it an RMB 50 bonus deduction, delivers a tax deduction of just RMB 120 following the application of the 80% cap). For payments to overseas service providers, while no 80% cap was applied, the super deduction bonus was denied. Under a new rule change, the disallowance of the super deduction bonus for payments to overseas service providers is abolished. As the 80% cap for payments to domestic service providers is still in place, this could mean that payments to overseas service providers will deliver a greater tax deduction. However, it remains to be seen if this cap might, in practice, be extended to payments to overseas service providers, as well. The new treatment is retroactively effective from January 1 2018, with detailed rules to follow.

  • China applies a general restriction of a five-year carry-forward period to tax losses. This will now be extended to 10 years for high and new technology enterprises (HNTEs) and science and technology SMEs. This recognises the fact that such enterprises may encounter several years of losses before a new innovation becomes profitable. The new treatment is retroactively effective from January 1 2018, with detailed rules to follow.

  • China applies a limitation to tax deductions for staff education expenses. The limit is set at 2.5% of the enterprise's salary bill, though a special 8% ceiling has applied for some time to advanced technology services enterprises (ATSEs) and HNTEs. The 8% limitation is now being expanded to all enterprises nationwide. The new treatment is retroactively effective from January 1 2018, with detailed rules to follow.

In addition to these new tax preferences for enterprise innovation, the government is also looking to foster the greater use of private pensions through individual income tax (IIT) regime changes. Private pensions are treated as the third of three pillars in China's pension insurance system. The mandatory first pillar is government schemes funded with social security contributions, and the second pillar is a voluntary or supplementary pension benefit called the enterprise annuity. In light of China's ageing population, the government has concluded that the third pillar needs to be bolstered further.

To this end, China is putting in place an exemption-exemption-taxation (EET) system of the sort in use in many other countries, such as the US's 401K regime. This is being piloted in Shanghai, Fujian and Suzhou Industrial Park from May 1 2018, and applies to so-called voluntary commercial endowment plans, a form of private retirement plan, as follows:

  • Contributions to an eligible commercial endowment insurance plan, deposited in an individual retirement account (IRA), are allowed to be deducted for IIT purposes;

  • Investment gains generated by the funds in the IRA are treated as tax exempt; and

  • IIT applies when the amounts in the IRA are withdrawn at retirement.

While the pilot programme is initially just in place for one year, where the government is satisfied with how the reform has proceeded, it may subsequently look to roll this programme out to the whole country.

ho-khoonming.jpg

lu-lewis.jpg

Khoonming

Ho

Lewis Lu

Khoonming Ho (khoonming.ho@kpmg.com) and Lewis Lu (lewis.lu@kpmg.com)

KPMG China

Tel: +86 (10) 8508 7082 and +86 (21) 2212 3421

Website: www.kpmg.com/cn

more across site & shared bottom lb ros

More from across our site

The US president’s threats expose how one superpower can subjugate other countries using tariffs as an economic weapon
The US president has softened his stance on tariffs over Greenland; in other news, a partner from Osborne Clarke has won a High Court appeal against the Solicitors Regulation Authority
Emmanuel Manda tells ITR about early morning boxing, working on Zambia’s only refinery, and what makes tax cool
Hany Elnaggar examines how AI is reshaping tax administration across the Gulf Cooperation Council, transforming the taxpayer experience from periodic reporting to continuous compliance
The APA resolution signals opportunities for multinationals and will pacify investor concerns, local experts told ITR
Businesses that adopt a proactive strategy and work closely with their advisers will be in the greatest position to transform HMRC’s relief scheme into real support for growth
The ATO and other authorities have been clamping down on companies that have failed to pay their tax
The flagship 2025 tax legislation has sprawling implications for multinationals, including changes to GILTI and foreign-derived intangible income. Barry Herzog of HSF Kramer assesses the impact
Hani Ashkar, after more than 12 years leading PwC in the region, is set to be replaced by Laura Hinton
With the three-year anniversary of the PwC tax scandal approaching, it’s time to take stock of how tax agent regulation looks today
Gift this article