I have just got my hands on a copy of new draft M&A procedural tax rules that should be released in the very near future. The copy I have has not been formally released at this stage so it may be subject to some changes, although this is doubtful. I havent had a chance to properly review the rules yet but I will try and give an outline of some of the salient points later today/tomorrow.

For a taste test, from my quick glance it appears that there is a new explanation of the reasonable business purpose test. These new draft rules are basically a further explanation of Caishui [2009] 59 (财税[2009] 59) which are the current tax rules governing M&A transactions in China.