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According to the STA Notice on Some Tax Treatment Issues During the Implementation of the Corporate Income Law (Guo Shui Han [2009] No.202), when calculating the pretax deduction cap for advertising expenses and business publicity expenses, enterprises should determine the sales (business) revenue – which should include main business income, other business income, and deemed sales (business) income stipulated in the Article 25 of the Implementation Regulations for the Corporate Income Tax Law. Deduction of advertising and business publicity expenses under a sharing agreement with associated enterprises In the case of associated enterprises that have entered into an advertising or business promotion expenses sharing agreement (hereafter the “sharing agreement”), the advertising fees incurred by one party, which do not exceed the pretax deduction cap, may be deducted by the said party, or may be transferred fully or partially to the other party in the sharing agreement.

Ministry of financeTaxation administrationState taxation administrationPretax deductionBusiness publicity expensesImplementation regulationsCorporate income tax lawSome tax treatment issues duringCorporate income lawGuo shui hanCorporate income taxSeveral tax treatment issues relatingTaxable income amountCorporate income tax purposeஅமைச்சகம் ஆஃப் நிதிவணிக விளம்பரம் செலவுகள்