（PCPA注：非官方译本。当产生歧意时,应以法律中文原文为准。This English document is not an official translation．In case of discrepancy, the original Chinese version shall prevail.）

Reply from the State Administration of Taxation Concerning Issues Relevant to the Taxation of Income on Leaseback Business Conducted by Foreign-Invested Enterprises Engaged in Real Estate Development

State Administration of Taxation　　Guo Shui Han [2007] No．603　　May 31, 2007

To the national taxation bureau of Hunan Province:

Your Request for Instruction Concerning Enterprise Income Tax Issues Relevant to Leaseback Business Conducted by Enterprises Engaged in Real Estate Development (Xiang Guo Shui Fa [2006] No．106) has been received and reviewed．Our reply is as follows:

I．Where a foreign-invested enterprise engaged in real estate development transfers, by means of sale, the buildings, structures, or other immovable property that they have produced or otherwise developed, and then proceeds to lease said property back from the purchaser, then, irrespective of the method by which the leasing occurs, all leaseback business shall, for the purposes of t