v3.26.1
Taxation
12 Months Ended
Dec. 31, 2025
Income Tax Disclosure [Abstract]  
Taxation

8. Taxation

 

a) Income taxes

 

Cayman Islands

 

Under the current laws of the Cayman Islands, the Company is not subject to tax on income or capital gain. Additionally, upon payments of dividends by the Company in the Cayman Islands to its shareholders, no Cayman Islands withholding tax will be imposed.

 

British Virgin Islands

 

Under the current laws of the British Virgin Islands, entities incorporated in British Virgin Islands are exempted from income tax on their foreign-derived incomes in the BVI. There are no withholding taxes in the BVI.

 

Singapore

 

Under the Singapore tax laws, subsidiaries in Singapore are subject to a unified 17% tax rate, except for certain entities that are entitled to preferential tax treatments, and there are no withholding taxes in Singapore on remittance of dividends. For the years ended December 31, 2023, 2024 and 2025, the Company’s Singapore entity recognized income tax (credit)/expense amounted to RMB(0.1) million, nil and RMB0.3 million, respectively, for the assessable profits base on the existing legislation, interpretation and practice of Singapore.

 

Hong Kong

 

Subsidiaries incorporated in Hong Kong are subject to Hong Kong profits tax at a two-tiered regime under which the tax rate is 8.25% for assessable profits on the first HK$2 million and 16.5% for any assessable profits in excess of HK$2 million. As an anti-avoidance measure, a group of “connected entities” can only nominate one entity within the Group to enjoy the reduced tax rate for a given year of assessment.

 

China

 

Under the Enterprise Income Tax Law of the PRC, the Company’s Chinese subsidiaries, VIEs and subsidiaries of the VIEs are subject to an income tax of 25%, except for Guangzhou Lizhi, Guangzhou Huanliao and Guangzhou Tiya. Due to their current status of entitled High and New Technology Enterprise (“HNTE”), Guangzhou Lizhi and Guangzhou Huanliao enjoy a preferential tax rate of 15% for the year ended December 31, 2023, 2024 and 2025. Guangzhou Tiya was granted HNTE and enjoy a preferential tax rate of 15% from December 9, 2025 to December 9, 2028. This status is subject to annual evaluation and a requirement that Guangzhou Lizhi, Guangzhou Huanliao and Guangzhou Tiya reapply for HNTE status every three years.

 

 

SOUND GROUP INC.

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

(All amounts in thousands, except for share, ADS, per share and per ADS data)

 

8. Taxation (Continued)

 

a) Income taxes (Continued)

 

China (Continued)

 

According to a policy promulgated by the State Tax Bureau of the PRC and effective from 2008 onwards, enterprises engaged in research and development activities are entitled to claim an additional tax deduction amounting to 50% of the qualified research and development expenses incurred in determining its tax assessable profits for that year. The additional tax deducting amount of the qualified research and development expenses have been increased from 50% to 75%, effective from 2018 onwards, according to a new tax incentives policy promulgated by the State Tax Bureau of the PRC in September 2018 (“Super Deduction”). The additional tax deducting amount of the qualified research and development expenses have been increased from 75% to 100%, effective from 2023 onwards.

 

Qualified subsidiaries and VIEs of the Group claimed the Super Deduction in ascertaining the tax assessable profits for the periods reported.

 

The enterprise income tax (“EIT”) Law also imposes a withholding income tax of 10% on dividends distributed by a foreign-invested entity (“FIE”) to its immediate holding company outside of China, if such immediate holding company is considered as a non-resident enterprise without any establishment or place within China or if the received dividends have no connection with the establishment or place of such immediate holding company within China, unless such immediate holding company’s jurisdiction of incorporation has a tax treaty with China that provides for a different withholding arrangement. The Cayman Islands, where the Company incorporated, does not have such tax treaty with China. According to the arrangement between Mainland China and Hong Kong Special Administrative Region on the Avoidance of Double Taxation and Prevention of Fiscal Evasion in August 2006, dividends paid by a FIE in China to its immediate holding company in Hong Kong will be subject to withholding tax at a rate that may be lowered to 5% (if the foreign investor owns directly at least 25% of the shares of the FIE). The State Administration of Taxation (“SAT”) further promulgated Circular 601 on October 27, 2009, which provides that tax treaty benefits will be denied to “conduit” or shell companies without business substance and that a beneficial ownership analysis will be used based on a “substance-over-form” principle to determine whether or not to grant the tax treaty benefits. Further, the SAT promulgated the Notice on Issues Related to the “Beneficial Owner” in Tax Treaties in February 2018, which requires the “beneficial owner” to have ownership and the right to dispose of the income or the rights and properties giving rise to the income and generally engage in substantive business activities and sets forth certain detailed factors in determining the “beneficial owner” status.

 

To the extent that subsidiaries, VIEs and subsidiaries of the VIEs of the Group have undistributed earnings, the Company will accrue appropriate expected withholding tax associated with repatriation of such undistributed earnings. For the year ended December 31, 2024 and 2025, the Group resolved to have one of its PRC subsidiaries, Guangzhou Tiya, declare and distribute cash dividends out of part of its retained earnings, amounting to RMB8.0 million and RMB18.0 million, respectively, to its immediate overseas parent company, Tiya HK. Accordingly, Guangzhou Tiya was required to pay and paid withholding taxes of RMB0.8 million and RMB1.8 million, respectively.

 

The Group has a plan to indefinitely reinvest its aggregate undistributed earnings and reserves and any future earnings in the PRC for use in the operation. Accordingly, no deferred tax liability on 10% withholding tax of aggregate undistributed earnings and reserves of the Company’s subsidiaries located in the PRC has been accrued that would be payable upon the distribution of those amounts to the Company as of December 31, 2024 and 2025.

 

Others

 

Subsidiaries incorporated in other countries are subject to the respective applicable corporate income tax rates of the countries where they are resident. For the years ended December 31, 2023, 2024 and 2025, the Company’s overseas others entity recognized income tax expense amounted to RMB0.4 million, RMB0.8 million and RMB0.8 million, respectively.

 

Income tax expense comprises:

 

   2023   2024   2025 
   For the year ended December 31, 
   2023   2024   2025 
             
Current income tax   434    2,475    731 
Withholding tax expense   -    786    2,050 
                
Total   434    3,261    2,781 

 

 

SOUND GROUP INC.

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

(All amounts in thousands, except for share, ADS, per share and per ADS data)

 

8. Taxation (Continued)

 

a) Income taxes (Continued)

 

The following table presents a reconciliation of the differences between the statutory income tax rate and the Company’s effective income tax rate for the years ended December 31, 2023, 2024 and 2025:

 

   For the year ended December 31, 
   2023   2024   2025 
   %   %   % 
Statutory income tax rate of the PRC   25.0    25.0    25.0 
Tax rate difference from preferential tax treatments and statutory rate in other jurisdictions   (29.6)   (23.8)   (6.3)
Effect of withholding taxes   -    (1.0)   1.0 
Permanent differences(1)   25.4    43.0    (25.1)
Change in valuation allowances   (21.2)   (47.4)   6.8 
Effective income tax rate   (0.4)   (4.2)   1.4 

 

(1) The permanent differences mainly consist of additional super deduction for research and development expenditures, and certain non-deductible expenses.

 

As of December 31, 2025, certain entities of the Company had net operating tax loss carry forwards as follows:

 

   RMB 
     
Loss expiring in 2026   11,736 
Loss expiring in 2027   5,172 
Loss expiring in 2028   14,994 
Loss expiring in 2029   73,727 
Loss expiring in 2030   421,019 
Loss expiring in 2031   207,664 
Loss expiring in 2032   14,027 
Loss expiring in 2033   98,722 
Loss expiring in 2034   129,473 
Loss expiring in 2035   143,999 
Operating loss carryforwards   1,120,533 

 

b) Deferred tax assets and liabilities

 

The following table presents the tax impact of significant temporary differences that give rise to the deferred tax assets as of December 31, 2024 and 2025:

 

   December 31, 2024   December 31, 2025 
    RMB    RMB 
Deferred tax assets:          
Net operating tax loss carry forwards   136,584    137,997 
Contingent Liability Provisions   -    35 
Lease obligations   -    232 
Advertising expenses in excess of deduction limit   8    8 
Total deferred tax assets   136,592    138,273 
Less: valuation allowances   (136,592)   (138,273)
Net deferred tax assets   -    - 

 

The Group does not believe that sufficient positive evidence exists to conclude that the recoverability of deferred tax assets of certain entities of the Group is more likely than not to be realized. Consequently, the Group has provided full valuation allowances on the related deferred tax assets. The following table sets forth the movement of the aggregate valuation allowances for deferred tax assets for the years presented:

 

   Balance at January 1   Movement*   Balance at December 31 
    RMB    RMB    RMB 
2023   (108,601)   (8,262)   (116,863)
2024   (116,863)   (19,729)   (136,592)
2025   (136,592)   (1,681)   (138,273)

 

*The movement in valuation allowances were due to the changes of deferred tax assets recognized for net operating tax loss carry forwards, advertising expenses in excess of deduction limit and deferred revenue.

 

 

SOUND GROUP INC.

NOTES TO THE CONSOLIDATED FINANCIAL STATEMENTS (CONTINUED)

(All amounts in thousands, except for share, ADS, per share and per ADS data)