01 Policy overview
What does the policy mainly clarify?
Conclusion: Starting from January 1, 2023, enterprises that can accurately collect and account for R&D expenses may independently choose to enjoy the super deduction for R&D expenses in the first half of the year at the July prepayment; if not chosen, they may enjoy it uniformly at the October prepayment or annual settlement, and processing still follows the principles of actual occurrence, self-judgment, declaration to enjoy, and document retention for inspection.
The following "Kailing Practical Key Points" are for assisting understanding. For official content, please refer to the original text and source links later on the page.
02 Applicable objects
Which enterprises and transactions need attention?
Applicable circumstances: When an enterprise prepays enterprise income tax in July for the second quarter (quarterly prepayment) or June (monthly prepayment), if it can accurately collect and account for R&D expenses, it may, based on its actual production and operation situation, independently choose to enjoy the super deduction policy for R&D expenses for the first half of the year.
When an enterprise prepays enterprise income tax in October for the third quarter (quarterly prepayment) or September (monthly prepayment), if it can accurately collect and account for R&D expenses, it may independently choose to enjoy the super deduction policy for R&D expenses for the first three quarters of the year.
Not applicable or temporarily not applicable situations: If an enterprise cannot accurately collect and account for R&D expenses during the corresponding prepayment filing period, it does not meet the conditions for enjoying the benefit at that prepayment time point as stated in the announcement. This material does not specify other entity qualifications such as industry, enterprise type, or scope of R&D activities; relevant matters need to be judged in conjunction with existing regulations.
03 Policy changes
Compared with existing business processing, what changes are there?
New enjoyment timing: On the basis of the original two enjoyment time points of the October advance filing and the annual final settlement, a new enjoyment time point of the July advance filing has been added, allowing enterprises that meet the conditions for accurate aggregation and accounting to enjoy additional deduction for R&D expenses in the first half of the year.
Management requirements remain unchanged: Prepayment filing still adopts the handling method of "actually incurred, self-judged, benefit claimed in filing, and relevant materials retained for inspection." Enterprises calculate the additional deduction amount themselves and fill in the prescribed filing forms and detailed schedules.
Document integration: This announcement takes effect from January 1, 2023, and the State Taxation Administration Announcement No. 10 of 2022 is simultaneously repealed. The announcement does not provide the super deduction ratio, expense scope, or other qualification conditions, which need to be judged in conjunction with existing regulations.
04 Execution list
What preparations should enterprises complete?
- Confirm the corporate income tax prepayment method, distinguishing quarterly prepayment from monthly prepayment, corresponding to the July and October prepayment filing time points.
- Based on actual R&D expenses incurred, accurately collect and account for R&D expenses for the first half of the year or the first three quarters of the year.
- Based on actual production and operation, independently determine whether to enjoy it at the July prepayment, October prepayment, or annual comprehensive settlement.
- Calculate the additional deduction amount yourself and file the "People's Republic of China Enterprise Income Tax Monthly (Quarterly) Prepayment Tax Return (Form A)."
- According to the R&D expenses for the first half of the year or the first three quarters corresponding to this preferential treatment, fill out the R&D Expense Super Deduction Preference Details Table (A107012).
- Keep the A107012 detail schedule together with other prescribed materials for inspection; if not chosen to be enjoyed during the prepayment period, arrange for subsequent prepayment filing or annual final settlement.
05 Risk Alert
What issues are most easily overlooked during implementation?
- Enjoying benefits in prepayment filing is premised on R&D expenses being accurately collected and accounted for, and this announcement should not be directly applied when accurate collection and accounting are impossible.
- The incentive is calculated based on actual R&D expenses incurred, and attention should be paid to keeping the declared amount consistent with the R&D expense aggregation and accounting.
- The A107012 detailed schedule and other prescribed materials must be retained for inspection, and it is not enough to complete only the prepayment filing while ignoring the retention of materials.
- The announcement does not state the additional deduction ratio, expense scope, or other qualification conditions. It is not appropriate to infer them solely based on this announcement; they need to be judged in light of existing regulations.
- Not choosing to enjoy it in July or October does not mean giving up the preference, but when enjoying it later, it must still be possible to accurately collect and account for R&D expenses.
06 Official Interpretation
How does the State Taxation Administration explain this policy?
To better support enterprise innovation and development, and in conjunction with the relevant requirements for comprehensively and solidly carrying out the thematic education on studying and implementing Xi Jinping Thought on Socialism with Chinese Characteristics for a New Era, the State Taxation Administration and the Ministry of Finance issued the "Announcement on Matters Concerning Optimizing the Policy for Enjoying the R&D Expense Super Deduction in Advance Tax Prepayment Filings" (No. 11 of 2023, hereinafter referred to as the "Announcement"). The relevant issues are interpreted as follows:
I. What is the main background for the issuance of the Announcement?
Before 2021, the super deduction policy for R&D expenses was enjoyed during the annual corporate income tax settlement and payment. In 2021, with the approval of the State Council, our bureau issued the Announcement on Matters Concerning Further Implementation of the Super Deduction Policy for R&D Expenses (No. 28 of 2021), allowing enterprises to enjoy the super deduction policy for R&D expenses of the first three quarters when making the October 2021 prepayment declaration. In 2022, to further stabilize policy expectations, our bureau issued the Announcement on Matters Concerning Enterprises Enjoying the Preferential Policy of Super Deduction for R&D Expenses in Prepayment Declarations (No. 10 of 2022), institutionalizing and making permanent the measure for enterprises to enjoy the super deduction policy for R&D expenses in the October prepayment declaration.
Since the policy allowing enterprises to enjoy the R&D expense additional deduction during the October prepayment filing was implemented two years ago, it has operated well, advancing the time when enterprises enjoy the preference by 3-8 months, enabling enterprises to enjoy policy benefits earlier and easing funding pressure. In the survey for studying and implementing Xi Jinping Thought on Socialism with Chinese Characteristics for a New Era, some enterprises reported that currently they can only enjoy the R&D expense additional deduction at two time points: the October prepayment filing period and the annual final settlement period the following year. They suggested adding more time points allowed for filing and enjoyment, so that enterprises can further enjoy policy benefits earlier. In accordance with General Secretary Xi Jinping's requirement to "persist in learning while comparing, inspecting, and rectifying, integrate problem rectification throughout the thematic education, and let the people truly feel the actual results of solving problems," we carefully studied the issues raised by enterprises and drafted the Announcement, allowing enterprises to enjoy the additional deduction policy for R&D expenses incurred in the first half of the year when filing the July prepayment, that is, on the basis of the original two enjoyment time points of October prepayment filing and annual final settlement, adding one more enjoyment time point and advancing the time when enterprises enjoy the preference by another three months.
II. What are the main changes in the Announcement?
According to the Announcement of the State Taxation Administration on Matters Concerning Enterprises Enjoying the Preferential Policy of Super Deduction for R&D Expenses During Prepayment Filing (No. 10 of 2022), the Announcement of the State Taxation Administration on Issuing the Revised Announcement (No. 23 of 2018), and other provisions, enterprises may enjoy the super deduction policy for R&D expenses during October prepayment filing and annual final settlement. On the basis of the above two time points, the Announcement adds one more time point for enjoyment: when filing enterprise income tax in July for the second quarter (quarterly prepayment) or June (monthly prepayment), if R&D expenses can be accurately collected and accounted for, enterprises are allowed to enjoy the super deduction policy for R&D expenses incurred in the first half of the year.
III. If an enterprise does not choose to enjoy the R&D expense additional deduction policy at the time of July prepayment declaration, can it still enjoy it later?
For enterprises that did not choose to enjoy the preferential treatment during the July prepayment filing period, if they can accurately collect and account for R&D expenses during the October prepayment filing or the annual final settlement, they may, based on their actual production and operation situation, independently choose to enjoy it uniformly during the October prepayment filing or the annual final settlement.
IV. Compared with Announcement No. 10, what changes are there in the management requirements for enterprises to enjoy the R&D expense super deduction policy during prepayment filing?
The administrative requirements specified in the Announcement for enterprises to enjoy the R&D expense super-deduction policy at the time of advance filing are consistent with the requirements of Announcement No. 10, with no changes. Specifically: enterprises enjoying the R&D expense super-deduction preferential policy adopt the handling method of "actual occurrence, self-determination, enjoy upon filing, and retain relevant materials for future reference." Enterprises shall, based on the actual R&D expenses incurred, calculate the super-deduction amount on their own, fill out the PRC Enterprise Income Tax Monthly (Quarterly) Prepayment Tax Return (Form A) to enjoy the tax preference, and fill out the R&D Expense Super-Deduction Preference Details Table (A107012) based on the R&D expenses for which the super-deduction preference is enjoyed (first half of the year or first three quarters). The R&D Expense Super-Deduction Preference Details Table (A107012) shall be retained together with other prescribed materials for future reference.
07 Original Policy Text
State Taxation Administration, Ministry of Finance Announcement No. 11 of 2023
To better support enterprise innovation and development, in accordance with "Enterprise Income Tax Law of the People's Republic of China" and its implementing regulations and other relevant provisions, the following announcement is hereby made on matters concerning optimizing the policy for enjoying the R&D expense super deduction during prepayment filing:
I. When an enterprise makes the July prepayment filing for enterprise income tax for the second quarter (quarterly prepayment) or June (monthly prepayment), if it can accurately collect and account for R&D expenses, it may, in light of its actual production and operation situation, independently choose to enjoy the additional deduction policy for R&D expenses for the first half of the year.
For enterprises that did not choose to enjoy the preferential treatment during the July prepayment filing period, if they can accurately collect and account for R&D expenses during the October prepayment filing or the annual final settlement, they may, based on their actual production and operation situation, independently choose to enjoy it uniformly during the October prepayment filing or the annual final settlement.
II. When an enterprise files its enterprise income tax prepayment for the third quarter (quarterly prepayment) in October or for September (monthly prepayment), if it can accurately aggregate and account for R&D expenses, it may, based on its actual production and operation situation, independently choose to enjoy the super deduction policy for R&D expenses for the first three quarters of the year.
For enterprises that did not choose to enjoy the preferential treatment during the October prepayment filing period, if they can accurately collect and account for R&D expenses during the annual final settlement, they may, based on their actual production and operation situation, independently choose to enjoy it uniformly during the annual final settlement.
III. Enterprises enjoying the preferential policy of additional deduction for R&D expenses shall adopt the handling method of "actually incurred, self-judged, enjoyed upon declaration, and relevant materials retained for inspection". Enterprises shall, based on actual R&D expenses incurred, calculate the additional deduction amount themselves, fill out the People's Republic of China Enterprise Income Tax Monthly (Quarterly) Prepayment Tax Return (Type A) to enjoy the tax preference, and fill out the R&D Expense Additional Deduction Preference Details Table (A107012) according to the R&D expenses for which the additional deduction preference is enjoyed (first half of the year or first three quarters). The R&D Expense Additional Deduction Preference Details Table (A107012) shall be retained for inspection together with other prescribed materials.
IV. This announcement shall take effect from January 1, 2023.Announcement of the State Taxation Administration on Matters Concerning Enterprises Enjoying the R&D Expense Super-Deduction Preferential Policy at the Time of Advance Filing(No. 10 of 2022) is simultaneously repealed.
Hereby announced.
State Taxation Administration, Ministry of Finance
June 21, 2023
08 FAQ
Issues of Enterprise Concern
At which points can enterprises enjoy the R&D expense super deduction through prepayment filing?
Enterprises that can accurately collect and account for R&D expenses may enjoy them for R&D expenses in the first half of the year when filing the July prepayment, or for R&D expenses in the first three quarters of the year when filing the October prepayment; enterprises may also enjoy them uniformly during the annual final settlement and payment in accordance with the announcement.
If you did not choose to enjoy it during the July prepayment filing, can you still enjoy it later?
Yes. If an enterprise does not choose to enjoy the preference during the July prepayment filing period, as long as it can accurately collect and account for R&D expenses later, it may, based on actual production and operation, independently choose to enjoy it uniformly during the October prepayment filing or the annual final settlement.
If the taxpayer still has not chosen to enjoy it at the time of the October prepayment filing, how should it be handled?
If an enterprise does not choose to enjoy the preference during the October prepayment filing period, and can accurately collect and account for R&D expenses during the annual final settlement, it may, based on its actual production and operation situation, enjoy the preference uniformly during the annual final settlement.
Which forms need to be filled in to enjoy benefits in prepayment filing?
Enterprises should file the "People's Republic of China Corporate Income Tax Monthly (Quarterly) Prepayment Tax Return (Form A)," and fill out the "R&D Expense Super Deduction Preference Details Table" (A107012) according to the R&D expenses for the first half of the year or the first three quarters corresponding to this preference. This details table should be retained together with other prescribed materials for inspection.
Does this announcement adjust the super deduction ratio or management method?
Official materials make clear that the management requirements for enjoying preferences through prepayment filing remain consistent with the original provisions, still implementing "actually incurred, self-determined, enjoy upon filing, retain relevant materials for future reference." This announcement does not provide or adjust specific super-deduction ratios; relevant ratios and other substantive conditions must be judged in conjunction with existing provisions.
Source and responsibility
Content source and responsibility information
- Official source
- State Taxation Administration, Ministry of Finance ↗
- Content organization
- Kailing Policy Research Group
- Review status
- Source and fact review completed
- Recently Updated
- 2026-07-27
This page does not constitute tax or legal advice; specific implementation shall be subject to the original policy text and the interpretation of the competent tax authority.