Laws of the People's Republic of China

Circular of the Ministry of Finance and the State Administration of Taxation Concerning the Collection of Enterprise Income Tax on the Increased Value due to Assets Assessment during the Restructuring of Industrial and Commercial Bank of China Limited

Cai Shui [2006] No. 81

The finance departments (bureaus), state taxation bureaus and local taxation bureaus of each province, autonomous region, municipality directly under the Central Government and city specifically designated in the state plan, the Finance Bureau of Xinjiang Production and Construction Corporations, and the financial supervision commissioners' offices of the Ministry of Finance in each province, autonomous region, municipality directly under the Central Government and city specifically designated in the state plan:

For the purpose of supporting the smooth operation of the restructuring and listing of the Industrial and Commercial Bank of China, the relevant issues concerning taxation are hereby announced as follows in accordance with relevant spirit of the State Council on supporting the restructuring of enterprises:

1.

Where the increased value due to assets assessment that occurs during the restructuring of Industrial and Commercial Bank of China has been confirmed and included into state capital by competent finance authorities, it shall be exempted from the enterprise income tax that should be paid subject to relevant provisions.

2.

The Industrial and Commercial Bank of China may make depreciation or amortization according to the assessed value of assets, and conduct deduction before the levy of enterprise income tax.

Please abide hereby.

The Ministry of Finance

The State Administration of Taxation

August 14, 2006