截至2010年底,中国累计批准设立的外商投资企业超过70万家。这些企业及作为其股东的非居民企业依经营管理或财务目标的需要,会调整其股权结构,其中,若发生股权转让,即会产生股权转让所得的企业所得税问题。同时,中国内外资统一适用的《企业所得税法》于2008年1月1日生效,取消了许多针对外资企业及其股东的优惠,也使非居民企业必须更加关注对中国 By the end of 2010, more than 700,000 foreign-invested enterprises had been approved by China. These enterprises and their non-resident enterprises, as their shareholders, will adjust their shareholding structure according to the needs of operation and management or financial goals. In the event of equity transfer, the enterprise income tax arising from equity transfer will be incurred. At the same time, the uniform application of the “Enterprise Income Tax Law” by Chinese and foreign investors came into effect on January 1, 2008, eliminating many preferential treatments for foreign-funded enterprises and their shareholders. It also required non-resident enterprises to pay more attention to China’s