在跨境重组交易中，如果涉及到中国公司的股权被转让，不论转让方是外籍个人还是外国公司，亦或者中国公司的股权是以何种方式被转让，直接转让还是间接转让，可能都会触发转让方在中国的纳税义务。本文通过案例具体介绍税收居民身份如何对跨境重组交易安排产生影响。

With rapid development of automobile electrification in recent years, automotive components and parts are being rapidly updated and iterated, especially core components and parts in connection with battery and battery management system. In general, automotive OEMs tend to subcontract part of such R&D to parts suppliers equipped with relevant knowhow, which has been a common R&D model. In the course of R&D, the suppliers would generally bear high R&D costs and other upfront investments, which would be amortized in purchase orders of parts formally placed by automotive OEMs after mass production. Under the above cooperation model, automotive OEMs are in a strong business position. If a pro-ject contract specifies no agreement on amount and payment of R&D, the suppliers might face high legal risks. Especially in the era when an increasing number of companies enter into NEV industry, many of such companies are incapable of affording tens of billions of investments in manufacturing vehicles, making it impossible to complete manufacture or mass production of ve-hicles or causing suspension of certain project. The following is an analysis of how such suppliers should claim R&D and other upfront costs against automotive OEMs in case of early termination of automotive parts R&D projects.

With increasingly widespread application of AI technology, many companies including traditional enterprises are undergoing digital transformation. In such context, it has been of great significance for companies to better deploy intellectual property (“IP”) to protect technological achievements. Meanwhile, the tightening state regulations on cybersecurity and privacy protection also bring new challenges to enterprises.