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

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

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 & shared bottom lb ros

More from across our site

Among the arrivals is Andrew Howell, who leaves scandal-hit PwC Australia after representing PepsiCo in a high-profile TP dispute
ITR's podcast examines whether the big four have overarching cultural issues and assesses the competitive threat of technology-backed transfer pricing firms
The UK advisory firm has seen its global revenues expand by £27.2m following its listing and acquisition of Baker Tilly South-East Europe
Tax-trained John Sams, previously the firm’s CFO and COO, was appointed after a rigorous process, KPMG said
From Mauritius substance rules to Kenyan SEP tax and South African anti-avoidance measures, businesses must navigate growing scrutiny of cross-border IP structures in Africa
ITR spoke to multinationals, advisers and software providers about a June 30 deadline defined by faulty portals, high compliance costs and hard lessons
After years of onerous pillar two prep, businesses will be galled in seeing tax revenues outweighed by compliance costs
Tax advisers should revisit India secondment arrangements after the EY US ruling strengthened the Centrica precedent and raised fresh withholding concerns
Despite the shortfall, effective tax rates of multinationals have seen a ‘statistically significant rise’
After joining Milbank from Akin Gump, the fund tax specialist discusses sponsor demand, practice building, and the tax challenges facing asset managers
Gift this article