Looking at China’s integrated circuit and software sector tax incentives

International Tax Review is part of Legal Benchmarking Limited, 4 Bouverie Street, London, EC4Y 8AX

Copyright © Legal Benchmarking Limited and its affiliated companies 2024

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

Looking at China’s integrated circuit and software sector tax incentives

Sponsored by

sponsored-firms-kpmg.png
Indonesia has moved ahead with the national implementation of the e-Faktur desktop application

Lewis Lu of KPMG discusses how policymakers have moved to incentivise production in China’s technology sector.

Chinese tax policymakers have made various efforts over the years to drive domestic innovation and enhance the economy’s competitiveness in high-tech sectors. To this end, the integrated circuit (IC) and software sectors have benefitted from a series of corporate income tax (CIT), VAT and import tax incentives since 2012.

In recent times, global trade restrictions have impacted the flow of high-end components to China, and so policymakers have further enhanced these incentives to support domestic production of these components.



In the CIT space, the key changes are: 

  • IC manufacturing enterprises and projects can benefit from tax holidays, with more generous benefits given to production of the newest and smallest chips. This varies from CIT exemption for 10 years (28NM circuits and 15 year planned operations), to five year exemption and five year half CIT rate (i.e. 12.5% vs the standard 25%) subsequently (65NM and 15 years operations), to two year exemption and three year half CIT rate (130NM and 10 years operations). The 28NM incentive is a policy effective from 2020.

  • For the eligible IC manufacturing enterprises, losses have a longer tax loss carry forward period (i.e., 10 years, vs the standard five years); and

  • Key IC design and software enterprises can be exempt from CIT for the first five years and then be subject to a 10% CIT rate for the subsequent years. Eligible enterprises will be identified by National Development and Reform Commission (NDRC) and Ministry of Industry and Information Technology (MIIT). 


Alongside the above, existing preferential VAT policies have been rolled over. A refund of carried forward excess input VAT balances may be granted to IC enterprises. Enterprises in China typically cannot get refunds and need to carry balances forward for future offset, so this is a preferred treatment. Software enterprise can enjoy a ‘refund-upon-levy’ policy, i.e. effective VAT burdens in excess of 3% can be refunded post-collection. 




For imports made by IC and software enterprises, an exemption is available from import duties and VAT. These tax incentives are available for both Chinese and foreign-invested enterprises. In parallel, the Chinese government has also set out preferential non-tax policies to facilitate IC and software enterprise conduct of initial public offerings (IPOs), financing, research and development (R&D) and talent cultivation. 



The IC industry, as well as other key high-tech sectors such as artificial intelligence (AI), biological medicine, and civil aviation, can also enjoy preferential CIT treatment in China’s free trade zones (FTZs). The Shanghai FTZ Lingang new area recently announced that, for enterprises engaged in the above-mentioned businesses, a 15% CIT rate can be applied for the first five years of establishment. Qualification requires substantive manufacturing or R&D activities.



China has also made efforts to cut red tape. The State Council recently announced plans to simplify filing procedures for VAT and other tax incentives, and eliminating pre-approval requirements. In parallel, the government authorities, including the NDRC, have set targets for the processing time for new business establishment to be capped at four working days by the end of 2020. 



Lewis Lu

T: +86 21 2212 3421

E: lewis.lu@kpmg.com





more across site & bottom lb ros

More from across our site

Taxpayers would have to register controlled commodity transactions and declare information to the Brazilian tax authorities under the proposed regulations
The Senate passed three bills with amendments that will enact the OECD’s 15% minimum corporate tax rate on multinationals
Despite fears that the UK’s increase in national insurance contributions could cripple some employers, those aspiring to equity partnership may spy a novel opportunity
ITR invites tax firms, in-house teams, and tax professionals to make nominations for the 2025 ITR Tax Awards in the Americas, EMEA, and Asia-Pacific
The US can veto anything proposed by the OECD, Alex Cobham of UK advocacy group Tax Justice Network argues
US partner Matthew Chen was named as potentially the first overseas PwC staffer implicated in the tax leaks scandal, in a dramatic week for the ‘big four’ firm
PwC alleged it has suffered identifiable loss and damage arising out of a former partner's unauthorised use of confidential information; in other news, Forvis Mazars unveiled its next UK CEO
Luxembourg saw the highest increase in tax-to-GDP ratio out of OECD countries in 2023, according to the organisation’s new Revenue Statistics report
Ryan’s VAT practice leader for Europe tells ITR about promoting kindness, playing the violincello and why tax being boring is a ‘ridiculous’ idea
Technology is on the way to relieve tax advisers tired by onerous pillar two preparations, says Russell Gammon of Tax Systems
Gift this article