Russia-China Cross-Border Taxation Guide

 

March 10, 2024

Anna Ivanova, Lawyer at BRACE Law Firm ©

 

As economic ties grow between Russia and the People's Republic of China (the "China" or the "PRC"), taxation has become a critical aspect of supporting international trade involving the import and export of goods between the two nations.

Specifically, when working with Chinese partners, it is essential to consider the taxation of imports and exports and pay close attention to the application of potential tax incentives introduced to support Russian and Chinese entrepreneurs. In practice, many questions also arise regarding VAT refunds in international trade. This article examines the fundamental features of taxation when conducting business between Russian and Chinese companies.

International Taxation Agreements for Transactions Between Russian and Chinese Companies

Currently, the Agreement between the Government of the Russian Federation and the Government of the People's Republic of China (the "Contracting States") On the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, dated October 13, 2014 (the "Double Taxation Treaty" or the "2014 Agreement"), is in effect. This treaty establishes that the existing taxes subject to the Agreement include, in China: individual income tax and enterprise income tax (the "Chinese tax"); and in Russia: corporate profit tax and individual income tax (the "Russian tax").

It should be noted that a similar Agreement dated May 27, 1994 (the "1994 Agreement") previously governed relations between the two countries. However, the development of bilateral economic ties and international taxation trends led to a mutual desire for adjustments. Due to the significant number of proposed changes, the parties concluded that entering into a new agreement was more appropriate than merely adopting a protocol to amend the existing one.[1]

Under the general rule of the 2014 Agreement, a resident of a Contracting State is any person who, under the laws of that State, is liable to tax therein by reason of their place of registration, place of effective management, or any other criterion of a similar nature.

If an organization (company) may be recognized as a resident of both Russia and China based on formal criteria, it is deemed a resident of the State where its place of effective management is located. Previously, prior to the effective date of the current agreement, corporate residency was determined by the location of the head office.

The term permanent establishment in the Agreement means a fixed place of business through which an enterprise carries on its business, in whole or in part. This specifically includes a place of management, a branch, an office, a factory, a workshop, a mine, an oil or gas well, a quarry, or any other place of extraction of natural resources (Article 5 of the Agreement).[2]

According to Article 23 of the Double Taxation Treaty, the profits of an enterprise of a Contracting State are taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein. If the enterprise carries on business through a permanent establishment, its profits may be taxed in the other State, but only to the extent attributable to that permanent establishment. If an enterprise of one State carries on business in the other State through a permanent establishment situated therein, each State shall attribute to that permanent establishment the profits it might be expected to make if it were a distinct and separate enterprise engaged in the same or similar activities and acting independently of the enterprise of which it is a permanent establishment.

In determining the profits of a permanent establishment, the States allow deductions for expenses incurred for the purposes of the permanent establishment, including executive and general administrative expenses. However, no profits shall be attributed to a permanent establishment merely by reason of the purchase of goods or merchandise by that permanent establishment for the enterprise.

Furthermore, under Article 22 of the Agreement, China eliminates double taxation in accordance with its laws as follows:

• If a resident of China derives income from Russia, the amount of tax paid in Russia on that income may be credited against the Chinese tax. However, the credit amount must not exceed the Chinese tax on that income.
• If the income derived from Russia consists of dividends paid by a company that is a resident of Russia to a company that is a resident of China and owns at least 20% of the company paying the dividends, the credit will take into account the tax paid in Russia by the company paying the dividends in respect of its income.

In Russia, double taxation is eliminated as follows: if a resident of Russia derives income from China, the amount of tax paid in China on that income may be credited against the Russian tax payable by that resident. However, the credit amount must not exceed the Russian tax on that income calculated in accordance with Russian tax laws and regulations (Article 22 of the 2014 Agreement).

Importantly, the Protocol dated October 13, 2014, is an integral part of the Agreement. It stipulates that any document or certificate of residence issued by a competent authority of a Contracting State or its authorized representative does not require legalization or an apostille for use in the other Contracting State, including use in courts or administrative bodies. This applies to documents obtained by the Contracting Parties as part of the exchange of information relevant to carrying out the provisions of the Agreement or for the administration or enforcement of domestic laws concerning taxes of every kind and description imposed on behalf of the Contracting States.

The Agreement does not apply to all territories of the PRC. As the Ministry of Finance of Russia clarifies, territories having an independent tax system where Chinese tax laws do not apply fall outside the scope of the Double Taxation Treaty. Such territories specifically include Taiwan.[3]

Tax Agreement with Hong Kong

The Hong Kong Special Administrative Region also maintains an independent tax system. In 2016, the Government of the Russian Federation and the Government of the Special Administrative Region of Hong Kong of the PRC entered into an Agreement on the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income. While the PRC imposes enterprise income tax and individual income tax, the existing taxes in Hong Kong include:

• Profits tax;
• Salaries tax;
• Property tax.

Article 7 of that Agreement sets forth the rules for corporate profits tax. The profits of an enterprise of a Contracting Party are taxable only in that Party unless the enterprise carries on business in the other Contracting Party through a permanent establishment. If the enterprise operates through a permanent establishment, its profits may be taxed in that other Party to the extent attributable to the permanent establishment.

Similar to the agreement with the PRC, the profits attributed to a permanent establishment are those it might be expected to earn if it acted entirely independently of the head office.

Additionally, in determining the profits of a permanent establishment, the Parties allow deductions for expenses incurred for the purposes of the permanent establishment, including executive and general administrative expenses. The Agreement with Hong Kong clarifies that the profits attributable to a permanent establishment must be determined by the same method year by year unless there is a good and sufficient reason to the contrary.[4]

In practice, the aforementioned Double Taxation Treaties contain similar provisions. The Ministry of Finance has issued several clarifications regarding the application of these provisions to practical issues.

For instance, the income of a foreign organization from business activities that do not result in a permanent establishment in the Russian Federation is not subject to taxation in the Russian Federation. Specifically, income from services provided by a foreign organization exclusively outside the Russian Federation does not constitute income from sources in the Russian Federation and is not subject to corporate profit tax withheld at the source in the Russian Federation.[5]

Furthermore, the development of relations between China and Russia has led to concession agreements and the creation of Russian-Chinese organizations acting as concessionaires. This has raised questions regarding whether a concessionaire organization may include interest on loan agreements as expenses. For example, a company building a bridge across a river between Russia and China submitted this question to the Ministry of Finance. The company was registered in China and opened a branch in Blagoveshchensk, Russia. The Ministry concluded that if the branch used funds obtained under the loan agreement to implement the Concession Agreement for the construction of the Russian part of the border bridge, and if the branch coordinated and controlled this construction (e.g., acting as the customer, selecting contractors, negotiating and entering into construction contracts, and accepting work and services), the branch may recognize the interest expenses on that loan as non-operating expenses for calculating corporate profit tax.[6]

Thus, the agreements between Russia and the PRC, and between Russia and Hong Kong, aim to create conditions where legal entities and individuals of both states are exempt from double taxation on the same income. They also seek to attract foreign investment to each Contracting State and exempt interest paid on loans and credits provided by banks of one state from taxation at the source in the other state.

It is important to note that besides operating through foreign representative offices, some Russian entrepreneurs choose to establish businesses in China by creating independent Chinese organizations fully subject to PRC law. Therefore, we will now examine the specific features of business taxation in China.

What Taxes are Paid in China?

Taxpayers in China include enterprises and other organizations (the "enterprises") that derive income within the PRC. Such taxpayers include state-owned enterprises, collective enterprises, associated enterprises, private enterprises, joint-stock enterprises, foreign-invested enterprises, and foreign enterprises, as well as institutions, social organizations, private non-profit organizations, and other organizations engaged in business activities. This also includes foreign companies and enterprises that derive income from China even if they do not have representative offices there. This category does not include individual proprietorships and partnerships created under Chinese laws and administrative regulations.[7]

In China, all enterprises are currently required to pay: 1) Income tax (the rate for non-residents is 20%); 2) VAT (rates range from 0% to 13%, depending on the company's activities).

Under Article 1 of the Enterprise Income Tax Law of the PRC, adopted by the Standing Committee of the National People's Congress on December 29, 2018 (the "China Enterprise Income Tax Law"), enterprises and other organizations deriving income within China must pay enterprise income tax. The tax rate for residents is 25%, while the rate for non-residents is 20% (Article 4).

According to Articles 6–9 of the China Enterprise Income Tax Law, an enterprise's total income consists of monetary and non-monetary income from various sources, including:

• Income from the sale of goods;
• Income from the provision of labor services;
• Income from property transactions;
• Income from dividends, bonuses, and other equity investments;
• Interest income;
• Rental income;
• Royalty income;
• Income from accepted donations;
• Other income.

Non-taxable income included in the total income consists of treasury appropriations, administrative fees, and government funds collected in accordance with the law and managed by the treasury.

When calculating the taxable amount, "reasonable expenses" actually incurred and related to the enterprise's business activities — including costs, expenses, taxes, and losses — are deducted from income. The enterprise may also deduct charitable donations not exceeding 12% of its total annual profit. Any excess over this 12% may be carried forward for three years when calculating taxable income.

Under Article 23 of the China Enterprise Income Tax Law, an enterprise may deduct from the taxable income for the current period the amount of income tax it has already paid abroad for the following:

• Taxable income derived by a resident enterprise outside China;
• Taxable income derived outside China by a non-resident enterprise with representative offices in China, provided the income is not actually connected to those offices.

According to Articles 53–54 of the China Enterprise Income Tax Law, enterprise income tax is calculated based on the tax year, which runs from January 1 to December 31. If an enterprise begins or ceases business operations mid-year, the actual period of operation is treated as the tax year.

Enterprise income tax must be paid in advance monthly or quarterly. The enterprise must submit an income tax return for the advance payment and pay the tax within 15 days of the end of the month or quarter.

Within five months after the end of each year, the enterprise must submit an annual enterprise income tax return to the tax authority to settle tax payments and calculate any tax due or refundable.[8]

Regarding VAT, the Government of the PRC issued the Provisional Regulations of the People's Republic of China On Value Added Tax in 1993 (the "1993 Provisional Regulations"). Subsequently, new provisional regulations came into force in 2009. In 2018, further changes were made to the VAT rules, reducing rates for certain goods and services. Currently, the applicable VAT system is governed by provisional regulations.[9]

Article 2 of the 1993 Provisional Regulations established that for taxpayers engaged in the sale or import of goods, the VAT rate was 17%. For taxpayers engaged in the sale or import of the following goods, the VAT rate was 13%: food grains, vegetable oils; tap water, heating, air conditioning, hot water, coal gas, liquefied petroleum gas, natural gas, methane, coal/briquettes for household use; books, newspapers, magazines; feed, chemical fertilizers, agricultural chemicals, and agricultural machinery.

For taxpayers engaged in the export of goods, the tax rate is 0% unless otherwise specified by the State Council. For taxpayers engaged in processing, repairs, and replacement (the "taxable services"), the rate is 17%. [10]

The VAT rates were modified again on April 1, 2019, under the new 2018 Provisional Regulations. The 17% rate was reduced to 13%, and the 13% rate was reduced to 9%. This reduction was driven by the slowing economic growth in China.[11] Consequently, the rate for manufacturing and sales is 13%, while the rate for transport services and real estate construction fell from 10% to 9%. The Chinese government continues to work on improving the tax system and enhancing the economy's competitiveness.[12]

On December 27, 2022, the National People's Congress presented a draft Value Added Tax Law of the People's Republic of China for discussion (the "Draft China VAT Law").

The Draft China VAT Law proposes a two-tier VAT system:

• Small-scale enterprises ("small-scale taxpayers") will be subject to a fixed VAT rate of 3%.
• General taxpayers will be subject to standard rates ranging from 13%, 9%, and 6%, depending on the type of supply.[13]

The new draft VAT law includes updated definitions of "taxable transactions" and "domestic taxable transactions."

Previously, either the seller or the buyer had to be located in China for a transaction to qualify as a domestic taxable transaction, regardless of where the goods or services were consumed. For example, a buyer in China purchasing goods from a seller outside China would be subject to VAT regardless of whether the buyer consumed the goods in China.

Now, the VAT depends on the goods or services themselves rather than the location of the buyer and seller. If a good is consumed in China, it is a domestic taxable transaction. Even if both the buyer and seller are outside China, if the transaction and consumption occur within China, the transaction is subject to VAT. [14]

Thus, Chinese tax law is currently undergoing significant changes aimed at accelerating economic growth. Russian entrepreneurs planning to open companies in China should carefully study the fundamental tax data and pre-calculate existing tax risks.

Importantly, as economic ties between Russia and China expand, several tax incentives have been introduced, which are discussed below.

Tax Incentives for Russian and Chinese Companies

Tax incentives in China are provided under Chapter 4 of the China Enterprise Income Tax Law. Articles 27–31 provide that the following income may be exempt from enterprise income tax or subject to reduced rates:

• Income derived from projects in agriculture, forestry, animal husbandry, and fisheries;
• Income derived from the business activities of major state-supported infrastructure investment projects;
• Income derived from environmental protection, energy-saving, and water-saving projects meeting relevant requirements;
• Income derived from the transfer of technologies meeting relevant requirements.

Small, low-profit enterprises meeting specified conditions are taxed at a reduced rate of 20%.

Enterprise income tax for key high-tech and new-tech enterprises requiring state support is collected at a reduced rate of 15%.

Additionally, an enterprise may calculate and deduct expenses for researching and developing new technologies and products, as well as wages paid to disabled employees or other workers whom the state encourages enterprises to hire.

A startup investment enterprise making major startup investments that require state support may deduct a certain portion of the investment amount from its taxable income.

Thus, China offers incentives to various enterprises depending on their business profile.

The Law of the People's Republic of China On Foreign Investment, dated February 24, 2021, approved by Order of the President of the People's Republic of China No. 26, establishes that the state protects the investments, income, and other lawful rights and interests of foreign investors in China in accordance with the law (Article 5). The state may, if necessary, create a special economic zone or implement pilot foreign investment policies and measures in specific areas to promote foreign investment and expand openness.[15]

China's tax system provides specific incentives for several areas treated as SEZs. These territories include:

• 90 state-level economic and technological development zones;
• 114 new and high-tech zones;
• 13 free trade zones;
• 14 state-level border economic cooperation zones;
• The Shanghai Free Trade Zone (SFTZ).[16]

From January 1, 2021, to December 31, 2024, enterprises registered in the Yangshan Special Comprehensive Bonded Zone of the Lingang New Area are exempt from VAT on income derived from providing transport, loading and unloading, and storage services within the zone.

Integrated circuit manufacturing enterprises are exempt from VAT for the first 10 years after their establishment. The state encourages enterprises engaged in information system and software design; they are exempt from VAT for the first two years and receive a 50% tax reduction (to 12.5%) for the following three years, starting from the enterprise's first profitable year.

The PRC provides incentives for "high and new technology" enterprises. A reduced profit tax rate for qualified taxpayers has been introduced, which is 15%. Such companies may also take a one-time pre-tax deduction for equipment and instruments (fixed assets other than houses and buildings) newly acquired between October 1, 2022, and December 31, 2022; a 100% deduction was allowed.

To receive these incentives, an enterprise must:

• Be registered in China (not including Hong Kong, Macau, and Taiwan) for at least one year;
• Own the intellectual property rights to the core technology of its key products or services through independent R&D, transfer, gift, merger and acquisition, etc.;
• Ensure that the core technology of its main products (services) falls within the "Advanced Technology Regions Strongly Supported by the State," which cover over 200 categories of technologies, products, and services in eight major technological areas;
• Ensure that the enterprise's technical personnel engaged in R&D and related technological innovation activities account for more than 10% of the total workforce in the current year;
• Over the last three fiscal years (or the actual period of operation for new entities), R&D expenses must constitute a certain percentage of the enterprise's total revenue for the same period:
  1. At least 5% if the last annual sales income is less than 50 million yuan (approximately $7.7 million);
  2. At least 4% if the last annual sales income is between 50 million yuan and 200 million yuan (approximately $7.7 million to $30.8 million);
  3. At least 3% if the last annual sales income exceeds 200 million yuan (approximately $30.8 million).[17]

Indirectly, incentives for business in China include the reduction of income tax for foreign workers. Under Circular No. 12 of the Ministry of Finance and the State Taxation Administration of the PRC, dated December 31, 2021, the rule allowing the deduction of expenses for housing, food, relocation, home visits, and Chinese language studies from income derived in the PRC was extended.[18]

Furthermore, to stimulate innovation, preferential tax regulations for newly acquired equipment remain in effect from 2023. This provision has existed since 2018; for equipment and devices newly acquired by enterprises with a unit value of less than 5 million yuan, such costs may be recorded as expenses for the current period and deducted in full when calculating taxable income.[19]

Thus, the PRC has introduced a substantial number of tax incentives to develop manufacturing, agriculture, and scientific research.

The legislation regarding business incentives in the PRC is constantly changing. Therefore, when planning operations in China, we recommend detailed monitoring of all new developments in both general and industry-specific regulations.

Russia also provides several opportunities to strengthen international economic ties with China. Specifically, general business support measures, such as tax holidays, apply to work with the PRC. Federal Law No. 477-FZ dated December 29, 2014, which has now been extended until January 1, 2025, introduces tax holidays for individual entrepreneurs. Specifically, Russian regions may establish a 0% tax rate for taxpayers who are individual entrepreneurs registered for the first time after these laws came into effect and who carry out business activities in the manufacturing, social, or scientific spheres. For example, St. Petersburg Law No. 185-36 dated May 5, 2009, On Establishing a Tax Rate in St. Petersburg for Organizations and Individual Entrepreneurs Applying the Simplified Taxation System, establishes a 0% rate for individual entrepreneurs applying the simplified taxation system who simultaneously meet the following conditions:

• Registered as individual entrepreneurs for the first time since January 1, 2016;
• Engage in specific types of economic activities, including manufacturing, production of unrefined palm oil and its fractions, wine production from grapes, metallurgical production, architecture and engineering-technical design, technical testing, research, and analysis.

Additionally, until the end of 2025, individual entrepreneurs and organizations are permitted to recover VAT in an accelerated manner. Federal Law No. 389-FZ dated July 31, 2023, On Amending Parts One and Two of the Tax Code of the Russian Federation, Certain Legislative Acts of the Russian Federation, and Suspending the Effect of the Second Paragraph of Clause 1 of Article 78 of Part One of the Tax Code of the Russian Federation, established the right to recover VAT without providing a bank guarantee or surety in an amount not exceeding the total amount of taxes and insurance contributions (excluding taxes paid in connection with moving goods across the Russian border and as a tax agent) paid for the calendar year preceding the year the application was filed (Subparagraph 8 of Clause 2, Clause 2.2 of Article 176.1 of the Tax Code of the Russian Federation).[20]

At the same time, Russia has not currently adopted China's experience in reducing VAT rates. The Russian Ministry of Finance notes that VAT practice shows that a reduction in the tax rate does not guarantee a decrease in the cost of goods (works, services).

Reducing the VAT rate would lead to a significant decrease in federal budget revenues, which cannot be supported at a time when federal budget expenditures are rising significantly. Furthermore, reducing this tax rate — a substantial change to the current system of indirect taxation — could negatively impact the economy as a whole and the participants in tax relations.

Regarding the application of the PRC's experience, the Russian Ministry of Finance maintains that the PRC economy is highly diversified and its VAT system is aimed at encouraging the production of high-processed goods through higher taxation of raw materials and the accelerated or increased deduction of VAT amounts charged by suppliers.

Currently, under Article 164 of the Tax Code of the Russian Federation, the VAT rate is 20%. However, current VAT legislation provides for a reduced rate of 10% on certain socially significant goods, including food and medical products and goods for children, as well as exemptions for social goods (works, services).

To support the export of goods manufactured in the Russian Federation and the most significant sectors of the economy, a 0% VAT rate is applied. This supports and grows domestic production, creates additional jobs, and increases the tax base for other taxes and contributions flowing into budgets at various levels.[21]

We will now examine the specific features of applying VAT to export operations in China and Russia in more detail.

Export VAT in China

Under China's VAT Regulations, an enterprise must pay VAT on the difference between output and input VAT.

Output VAT is the amount of VAT the enterprise charges on its sales of goods or services. Input VAT is the VAT the organization pays when purchasing raw materials, supplies, and services. Input VAT represents a commercial expense incurred in conducting business. This amount is used to offset the output VAT the enterprise accrues from sales.

However, as noted in this article, the VAT rate in the PRC for exports is 0% (output VAT), unless other rates are provided by the State Taxation Administration of the PRC.

In this case, there is no output VAT against which to credit input VAT.

To eliminate this imbalance for exporters, an export VAT refund scheme was introduced, providing for the full or partial reimbursement of input taxes paid. This allows relevant enterprises in China to claim a refund for VAT paid on purchases of goods or services related to the enterprise's provision of VAT-taxable goods or services. [22]

China's tax rules provide for three export refund regimes: the tax exemption regime, the "pay first, refund later" regime, and the "exemption-credit-refund" regime.

The tax exemption regime applies to goods that are exempt from output VAT at the point of export, such as self-produced goods or goods purchased from small-scale taxpayers. Exporters do not need to pay output VAT or apply for a refund.

The "pay first, refund later" regime applies to goods subject to output VAT at the point of export, such as goods not produced in-house or goods purchased from general taxpayers. Exporters must first pay the output VAT and then apply for a refund.

The exemption-credit-refund regime applies to goods subject to output VAT at the point of export but which can be offset by input VAT. Exporters do not need to pay output VAT but may apply for a refund of the input VAT amount that exceeds the output VAT. [23]

Thus, after completing an export transaction, an enterprise has the right to submit documents to the Chinese tax authorities (Local Taxation Bureau) for a VAT refund.

The practice of returning the tax on exports is a preferential state taxation measure in China for exporting enterprises. Under this measure, after products are exported, the tax authorities return to the enterprise payments of indirect taxes, such as VAT and excise tax, collected at various stages of production and circulation within China. Both Chinese and foreign companies are eligible for VAT refunds. [24]

The choice of refund method depends on the type of exporter and its business profile.

To recover VAT in China, the following documents must be submitted:

• Application for an export VAT refund;
• Business license;
• Sales or supply contracts, including export contracts, foreign trade service contracts, sales or supply contracts concluded with foreign trade entities, and contracts for the sale of goods produced by a third party and intended for export;
• Shipping and transport documents, such as waybills, bills of lading, and invoices.

Based on these documents, the China Taxation Bureau classifies the exporter as a state-owned, manufacturing, or trading company. The exporter's class directly affects the time required to review documents and reach a decision (from one to six months). If the decision is favorable, the VAT amounts are credited to the organization's bank account. If the export operation is not confirmed, the transaction is recognized as domestic, and VAT must be paid in full. [25]

Thus, the opportunities for VAT recovery in the PRC are aimed at developing both domestic business and business with foreign investment.

This article has examined the fundamental issues related to conducting business between Russian and Chinese companies. It is important to note that when applying the legal norms of Russia and the PRC governing taxation in practice, an individual approach is necessary for each transaction, along with the forecasting of potential risks and an analysis of aspects such as the business direction of the Russian or Chinese organization, company turnover, and other factors.

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References

[1] Zhernovoy M.V., Sukharenko A.N. Russian-Chinese Cooperation in the Sphere of Taxation // Taxes. 2016. No. 4. pp. 38–40.

[2] Agreement Between the Government of the PRC and the Government of the RF on the Avoidance of Double Taxation and the Prevention of Fiscal Evasion. 09.20.2016. Gladkikh, Murziyanova & Partners.

[3] Letter of the Ministry of Finance No. 03-08-05/64903 dated August 12, 2021, on double taxation.

[4] Agreement Between the Government of the Russian Federation and the Government of the Special Administrative Region of Hong Kong of the People's Republic of China On the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income. Concluded in Hong Kong on January 18, 2016.

[5] Letter of the Ministry of Finance of Russia No. 03-08-05/45777 dated May 19, 2023.

[6] Letter of the FAS Russia No. SD-4-3/3286@ dated March 17, 2022.

[7] Chen Gong. Finance (Sixth Edition) [M]. China Renmin University Press, 2019.

[8] Enterprise Income Tax Law of the PRC. Adopted by the Standing Committee of the National People's Congress on December 29, 2018.

[9] China VAT. Msadvisory.

[10] Provisional Regulations on VAT. Approved by the State Council of the PRC on December 13, 1993.

[11] Value Added Tax: Various Reform Paths in China and Russia. E.A. Dorofeeva // Pedagogical sciences. Colloquium-journal. No. 14 (33). 2019.

[12] VAT in China in 2024: Export and Import. Krasina A. March 15, 2023. Asia Caravan.

[13] China proposed VAT Law overhaul 2023. Vatcalc. January 22, 2023.

[14] China VAT Law Soon to Come Into Effect. Msadvisory. June 8, 2023.

[15] Law On Foreign Investment of the People's Republic of China. Approved by Order of the President of the People's Republic of China No. 26 dated February 24, 2021.

[16] Problems and Prospects for Improving VAT in China and Russia. I.A. Mayburov. Ural Federal University named after the first President of Russia B.N. Yeltsin. 2018.

[17] Tax Incentives for Foreign Invested Enterprises. China-briefing.

[18] Circular of the Ministry of Finance of the PRC and the State Taxation Administration of the PRC No. 12 dated December 31, 2021.

[19] China: Tax Benefits in 2023. Rödl & Partner. February 15, 2023.

[20] VAT Can Be Recovered in 2024 via the Declarative (Accelerated) Procedure. FAS Russia. January 22, 2024.

[21] Letter of the Tax Policy Department of the Ministry of Finance of Russia No. 03-07-14/71032 dated July 22, 2022, On Considering Proposals to Reduce the VAT Rate and Applying the Experience of the PRC.

[22] What is Export VAT Refund in China? CW CPA Empowering your China success with our trusted advisory. May 20, 2023.

[23] China Export Tax Refund Policy: Recent Changes and Implications. YouWin Consulting brings efficiency & transparency to your business in China. June 18, 2023.

[24] Secrets of Export VAT Recovery in China. Multiservice Platform for International Trade.

[25] Comparative Analysis of VAT Systems in Russia and China. O.M. Karpova, I.A. Mayburov // Izvestia FEFU. Economics and Management. No. 2. 2018. 68 – 76.