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National Certified Tax Adviser Professional Qualification Examination — Tax Law (II) (全国税务师职业资格考试 — 税法（二）) practice questions are available now; exam metadata is being verified.
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The China Certified Tax Adviser Tax Law II (税务师 税法二) examination is the definitive credential test for direct income taxation, property taxes, and international tax planning in China. Evaluated over 150 minutes with a 140-point full mark (84-point passing threshold), this 100-question English-language bank delivers rigorous calculation drills across Enterprise Income Tax adjustments, Individual Income Tax comprehensive calculations, Stamp Duty, Deed Tax, Real Estate Tax, and cross-border international tax rules.
Sample Certified Tax Adviser — Tax Law II Practice Questions
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1Under the Enterprise Income Tax Law of the PRC (中华人民共和国企业所得税法), which of the following enterprises is classified as a 'Resident Enterprise' (居民企业)?
A.An enterprise established under foreign laws whose place of effective management (实际管理机构) is located within the territory of China.
B.An enterprise established under foreign laws whose place of effective management is outside China, but has an operational branch in Shanghai.
C.An enterprise established under foreign laws that has no establishment or place of business in China but derives dividends from a Shenzhen company.
D.An enterprise established in Hong Kong SAR whose place of effective management and board meetings are held exclusively in Hong Kong.
Explanation: According to Article 2 of the PRC Enterprise Income Tax Law, a 'Resident Enterprise' refers to an enterprise established inside China under Chinese laws, OR an enterprise established under foreign (regional) laws but whose place of effective management (实际管理机构) is located within China. Resident enterprises are subject to PRC enterprise income tax on their worldwide income.
2A foreign manufacturing company (non-resident enterprise) sets up an operational branch in Beijing. In the current tax year, the Beijing branch earns RMB 8,000,000 from manufacturing consulting in China, RMB 2,000,000 from consulting services provided in Vietnam that are effectively connected (实际联系) to the Beijing branch, and RMB 1,000,000 from patent licensing in Germany that has no connection to the Beijing branch. What is the total taxable income scope subject to PRC EIT at the Beijing branch level?
A.RMB 8,000,000
B.RMB 10,000,000
C.RMB 11,000,000
D.RMB 2,000,000
Explanation: Under Article 3 of the PRC Enterprise Income Tax Law, a non-resident enterprise that establishes an organization or premises (机构、场所) in China must pay EIT on: (1) all income derived from sources inside China (RMB 8,000,000), and (2) income derived outside China that is effectively connected (发生在中国境外但与其机构、场所有实际联系) with such organization/premises (RMB 2,000,000). The total taxable income subject to EIT is RMB 8,000,000 + RMB 2,000,000 = RMB 10,000,000. Non-connected overseas income (RMB 1,000,000) is excluded.
3A Singapore company has no establishment or place of business in China. During 2025, it receives a dividend of RMB 5,000,000 from a resident enterprise in Shanghai and interest of RMB 1,000,000 from a loan extended to a resident enterprise in Guangzhou. Under the PRC Enterprise Income Tax Law, how is PRC EIT collected on these income items in the absence of tax treaty modifications?
A.The Singapore company must register for self-filing in China and pay 25% EIT on net profit.
B.The resident enterprises paying the income act as withholding agents (扣缴义务人) and withhold 10% EIT on the gross payment amount.
C.The income is exempt from PRC EIT because the Singapore company has no physical presence in China.
D.The Singapore company pays 20% EIT with a statutory 20% deemed cost deduction.
Explanation: Under Articles 3, 19, and 27 of the PRC Enterprise Income Tax Law and Article 91 of its Implementation Regulations, a non-resident enterprise with no establishment in China deriving China-sourced dividends, interest, rentals, royalties, or property gains is subject to withholding tax at source (源泉扣缴). The statutory rate is 20%, reduced to a preferential rate of 10% on the gross amount (without expense deduction), withheld directly by the paying enterprise (the withholding agent).
4Which of the following business organizational forms is EXCLUDED from the scope of taxpayers under the PRC Enterprise Income Tax Law?
A.State-owned sole proprietorship limited liability companies (国有独资有限责任公司)
B.Foreign-invested joint stock limited companies (外商投资股份有限公司)
C.General partnerships (普通合伙企业) and Individual sole proprietorship enterprises (个人独资企业)
D.Social organizations and private non-enterprise entities (社会团体和民办非企业单位)
Explanation: According to Article 1 of the PRC Enterprise Income Tax Law, individual proprietorship enterprises (个人独资企业) and partnership enterprises (合伙企业) are not subject to Enterprise Income Tax. Instead, they follow the pass-through principle (先分后税) and their individual investors/partners are subject to Individual Income Tax (个人所得税) on business operation income (经营所得).
5Under PRC Enterprise Income Tax regulations (Guoshuihan [2008] No. 828), which of the following asset transfer scenarios constitutes a 'Deemed Sale' (视同销售) requiring recognition of taxable revenue?
A.Transferring self-produced machinery from the head office in Beijing to an unincorporated manufacturing branch in Tianjin.
B.Using self-produced electronic appliances as gifts for external client promotion and marketing.
C.Transferring self-manufactured parts from raw materials inventory to work-in-progress for another production line within the same legal entity.
D.Changing the operational use of a commercial building from self-use office space to administrative staff training space.
Explanation: Under Guoshuihan [2008] No. 828 and EIT Implementation Regulations Article 25, when an enterprise transfers asset ownership outside the legal entity—such as using self-produced goods for external donations, client entertainment, advertising/promotion, sample distribution, or employee welfare—it is treated as a deemed sale for EIT purposes at fair market value. In contrast, internal asset transfers within the same legal entity (such as transferring assets between branches or changing internal usage) do not transfer ownership externally and do not trigger deemed sales revenue recognition.
6In December 2025, Company A (a resident enterprise) sells heavy machinery under an installment sales contract for a total price of RMB 12,000,000 (excluding VAT). The contract specifies that the buyer shall pay RMB 4,000,000 on December 20, 2025, RMB 4,000,000 on December 20, 2026, and RMB 4,000,000 on December 20, 2027. Goods were delivered on December 10, 2025. Due to buyer cash flow constraints, the first payment of RMB 4,000,000 was actually received on January 15, 2026. What amount of revenue should Company A recognize for Enterprise Income Tax purposes in tax year 2025?
A.RMB 12,000,000
B.RMB 4,000,000
C.RMB 0
D.RMB 8,000,000
Explanation: According to Article 23 of the Implementation Regulations of the PRC Enterprise Income Tax Law, for sales of goods by installment payments (分期收款方式销售货物), revenue shall be recognized on the agreed date of payment as specified in the sales contract (按照合同约定的收款日期确认收入的实现). Since the contract agreed payment date for the first installment was December 20, 2025, Company A must recognize RMB 4,000,000 of taxable revenue in 2025, regardless of whether the payment was actually collected on that date.
7A software enterprise enters into a contract on July 1, 2025, to develop customized enterprise resource planning (ERP) software for a client for a total contract price of RMB 6,000,000. The project duration is 18 months. As of December 31, 2025, the enterprise incurred development costs of RMB 1,800,000, and the estimated total cost to complete the project is RMB 4,500,000. How should the enterprise recognize EIT revenue for 2025?
A.Recognize RMB 0 in 2025 and defer all revenue until the ERP software is fully accepted in 2026.
B.Recognize RMB 2,400,000 based on the percentage of completion method (完工进度 / 完工百分比法).
C.Recognize RMB 6,000,000 immediately in 2025 upon contract signing.
D.Recognize RMB 1,800,000 equal to the actual incurred development costs in 2025.
Explanation: Under Article 23 of the EIT Implementation Regulations, where the provision of services or manufacturing of large equipment/construction spans across tax years and lasts for more than 12 months, revenue shall be recognized according to the percentage of completion (完工进度) or completed work volume at the end of the tax year. Here, Progress = Incurred Costs / Estimated Total Costs = RMB 1,800,000 / RMB 4,500,000 = 40%. Taxable revenue for 2025 = RMB 6,000,000 * 40% = RMB 2,400,000.
8Under State Taxation Administration (STA) Announcement [2010] No. 19, at which point in time must an enterprise recognize revenue from the transfer of equity (股权转让收入) for Enterprise Income Tax purposes?
A.On the date when the equity transfer agreement is signed by both parties.
B.On the date when the transferor receives the initial earnest money deposit.
C.On the date when the equity transfer agreement becomes effective and the enterprise completes the legal registration change (工商变更登记) or equity transfer procedures.
D.On the date when the full transfer consideration is completely settled and deposited into the transferor's bank account.
Explanation: According to STA Announcement [2010] No. 19, revenue from the transfer of equity shall be confirmed when the equity transfer agreement takes effect and the enterprise completes the industrial and commercial registration change procedures (股权转让协议生效且完成股权变更手续时) or the transfer of equity rights is legally effected.
9On October 1, 2025, Enterprise X leases a commercial warehouse to Tenant Y for a 3-year term ending September 30, 2028. Pursuant to the contract, Tenant Y pays the entire 3-year rent of RMB 3,600,000 (excluding VAT) in a lump sum on October 15, 2025. Under STA Announcement [2010] No. 19, how may Enterprise X recognize this rental income for EIT purposes?
A.Enterprise X must recognize all RMB 3,600,000 as taxable income in 2025 on a cash basis.
B.Enterprise X may recognize the rental revenue evenly over the 3-year lease term (分期均匀计入相关年度收入), recognizing RMB 300,000 (3 months) in 2025.
C.Enterprise X must defer all revenue until the expiration of the lease contract in 2028.
D.Enterprise X is exempt from EIT on rental income paid more than 12 months in advance.
Explanation: Under Article 19 of the EIT Implementation Regulations and STA Announcement [2010] No. 19, while rental income is generally recognized on the contractually agreed payment date, if the lease agreement stipulates a lump-sum advance payment of rent spanning multiple tax years, the lessor may evenly allocate the rental income across the corresponding rental period (分期均匀计入相关年度收入) in accordance with the matching principle. In 2025 (3 months from Oct to Dec), the allocated revenue is RMB 3,600,000 / 36 * 3 = RMB 300,000.
10Which of the following receipts qualifies as 'Non-Taxable Income' (不征税收入) under Article 7 of the PRC Enterprise Income Tax Law and Caishui [2011] No. 70?
A.Interest income derived from holding Treasury bonds (国债利息收入).
B.Dividend income received by a resident enterprise from direct equity investment in another resident enterprise.
C.Fiscal funds (财政性资金) allocated by a municipal government with specific designated purpose, special fund management requirements, and an expenditure tracking mandate.
D.Income derived by a manufacturing enterprise from the sale of waste materials and scrap inventory.
Explanation: According to Article 7 of the PRC EIT Law and Caishui [2011] No. 70, fiscal funds (财政性资金) allocated by governments at or above the county level that simultaneously meet 3 conditions—(1) clear designated fund purpose documents, (2) specialized financial management methods, and (3) separate accounting/tracking of expenditures—qualify as Non-Taxable Income (不征税收入). Note that costs/depreciation associated with non-taxable funds cannot be deducted.
About the Certified Tax Adviser — Tax Law II Practice Questions
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