On 28 December 2017, four PRC government bodies, namely the Ministry of Finance (“MOF”), State Administration of Taxation (“SAT”), National Development and Reform Commission (“NDRC”) and Ministry of Commerce (“MOC”) jointly issued Caishui  88 (“Caishui 88”), which clarifies the criteria to enjoy the withholding tax (“WHT”) treatment, application procedures and responsibilities, and post-administration by the tax authorities.
Subsequently, the SAT issued one public note  No.3 (“Public Note No.3”) and an official interpretation to further elaborate the Caishui 88.
The treatment would be effective retrospectively from 1 January 2017, and tax payments already settled on eligible re-investment can be refunded. The above four ministries also jointly released a list of Questions and Answers through the MOF’s official website on 28 December 2017. Readers can also refer to the website on their interpretations.