Laws of the People's Republic of China

the Ministry of Finance, the State Administration of Taxation

Circular of the Ministry of Finance and the State Administration of Taxation on the Business Tax Policies for Qualified Foreign Institutional Investors

Cai Shui [2005] No. 155

The financial departments (bureaus) and local tax bureaus of all provinces, autonomous regions, municipalities directly under the Central Government and the cities specifically designated in the State plan and the Financial Bureau of Xinjiang Production and Construction Corps.

Upon approval of the State Council, the business tax policies for qualified foreign institutional investors (hereinafter referred to as QFII) are hereby notified as follows:

The difference revenues of the QFIIs derived from buying and selling of securities conducted in China by the domestic companies on behalf of the QFIIs shall be exempt from the business tax.

Please implement this policy accordingly.

Ministry of Finance

State Administration of Taxation

December 1, 2005