Note 19 - Taxation

12 Months Ended

Dec. 31, 2015

Income Tax Disclosure [Abstract]

Income Tax Disclosure [Text Block]

19. Taxation

1) Income tax

The entities within the Company file separate tax returns in the respective tax jurisdictions in which they operate.

i). The Company is incorporated in the state of Nevada. Under the current law of Nevada, the Company is not subject to state corporate income tax. Following the Share Exchange, the Company became a holding company and does not conduct any substantial operations of its own. No provision for federal corporate income tax has been made in the financial statements as the Company has no assessable profits for the year ended December 31, 2015, or any prior periods. The Company does not provide for U.S. taxes or foreign withholding taxes on undistributed earnings from its non-U.S. subsidiaries because such earnings are intended to be reinvested indefinitely. If undistributed earnings were distributed, foreign tax credits could become available under current law to reduce the resulting U.S. income tax liability.

ii). China Net BVI was incorporated in the British Virgin Islands (“BVI”). Under the current law of the BVI, China Net BVI is not subject to tax on income or capital gains. Additionally, upon payments of dividends by China Net BVI to its shareholders, no BVI withholding tax will be imposed.

iii). China Net HK was incorporated in Hong Kong and does not conduct any substantial operations of its own. No provision for Hong Kong profits tax has been made in the financial statements as China Net HK has no assessable profits for the year ended December 31, 2015 or any prior periods. Additionally, upon payments of dividends by China Net HK to its shareholders, no Hong Kong withholding tax will be imposed.

iv). The Company’s PRC operating subsidiaries and VIEs, being incorporated in the PRC, are governed by the income tax law of the PRC and is subject to PRC enterprise income tax (“EIT”). The EIT rate of PRC is 25%, which applies to both domestic and foreign invested enterprises.

l In July 2012, Business Opportunity Online was approved by the related PRC governmental authorities as a High and New Technology Enterprise under the current EIT law, and was approved by the local tax authorities of Beijing, the PRC, to be entitled to a favorable statutory tax rate of 15% until December 31, 2014. During 2015, Business Opportunity Online reapplied for the qualification as a High and New Technology Enterprise. In November 2015, Business Opportunity Online received the formal certificate as a High and New Technology Enterprise, which enabled the entity to continue to enjoy the favorable statutory tax rate of 15% until November 2018. Therefore, for the years ended December 31, 2015 and 2014, the applicable income tax rate of Business Opportunity Online was both 15%.

l Business Opportunity Online Hubei was approved by the related PRC governmental authorities to be qualified as a software company and was approved by the local tax authorities of Xiaogan City, Hubei province, the PRC, to be entitled to a EIT exemption for fiscal 2012 and a 50% reduction of its applicable EIT rate which is 25% to 12.5% of its taxable income for the succeeding three years through fiscal 2015, as its first profitable year was determined as fiscal 2011 instead of fiscal 2012 in August 2013 by the local tax authorities of Xiaogan City, Hubei province. Therefore, the applicable income tax rate for Business Opportunity Online Hubei was both 12.5% for the years ended December 31, 2015 and 2014. After fiscal 2015, the applicable income tax rate for Business Opportunity Online Hubei will be 25% under the current EIT law of PRC.

l The applicable income tax rate for other PRC operating entities of the Company is 25% for the years ended December 31, 2015 and 2014.

l The current EIT law also imposed a 10% withholding income tax for dividends distributed by a foreign invested enterprise to its immediate holding company outside China. A lower withholding tax rate will be applied if there is a tax treaty arrangement between mainland China and the jurisdiction of the foreign holding company. Holding companies in Hong Kong, for example, will be subject to a 5% withholding tax rate.

For the years ended December 31, 2015 and 2014, all of the preferential income tax treatments enjoyed by the Company’s PRC subsidiaries and VIEs were based on the current applicable laws and regulations of the PRC and approved by the related government regulatory authorities and local tax authorities where the Company’s respective PRC subsidiaries and VIEs operate in. Business Opportunity Online and Business Opportunity Online Hubei were most affected by these preferential income tax treatments within the structure of the Company. The preferential income tax treatments are subject to change in accordance with the PRC government economic development policies and regulations. These preferential income tax treatments are primarily determined by the regulation and policies of the PRC government in the context of the overall economic policy and strategy. As a result, the uncertainty of theses preferential income tax treatments are subject to, but not limited to, the PRC government policy on supporting any specific industry’s development under the outlook and strategy of overall macroeconomic development.

2) Turnover taxes and the relevant surcharges

Service revenues provided by the Company’s PRC operating subsidiaries and VIEs were subject to Value Added Tax (“VAT”). VAT rate for provision of modern services (other than lease of corporeal movables) is 6% and for small scale taxpayer, 3%. Therefore, for the years ended December 31, 2015 and 2014, the Company’s service revenues are subject to VAT at a rate of 6%, after deducting the VAT paid for the services purchased from suppliers, or at a rate of 3% without any deduction of VAT paid for the services purchased from suppliers. The surcharges of the VAT is 12%-14% of the VAT, depending on which tax jurisdiction the Company’s PRC operating subsidiaries and VIE operate in.

As of December 31, 2015 and 2014, taxes payable consists of:

	As of December 31,
	2015		2014
	US$(’000)		US$(’000)
Turnover tax and surcharge payable		1,272		1,173
Enterprise income tax payable		1,914		2,159
		3,186		3,332

A reconciliation of the income tax benefit determined at the U.S. federal corporate income tax rate to the Company’s effective income tax benefit is as follows:

	Year Ended December 31,
	2015			2014
	US$(’000)			US$(’000)
Pre-tax loss		(9,212	)		(12,946	)
U.S. federal rate		35	%		35	%
Income tax benefit computed at U.S. federal rate		3,224			4,531
Reconciling items:
Rate differential for domestic earnings		(647	)		(762	)
Preferential tax treatments and tax holiday effects		(16	)		(176	)
Valuation allowance on deferred tax assets		(1,057	)		(2,269	)
Goodwill impairment loss		-			(938	)
Others		(8	)		92
Effective income tax benefit		1,496			478

For the years ended December 31, 2015 and 2014, the Company’s income tax benefit consisted of:

	Year Ended December 31,
	2015			2014
	US$(’000)			US$(’000)
Current-PRC		(4	)		(185	)
Deferred-PRC		1,500			663
Income tax benefit		1,496			478

The Company’s deferred tax liabilities at December 31, 2015 and changes for the two years then ended were as follows:

	Amount
	US$(’000)
Balance as of December 31, 2013		1,439
Reversal during the year		(474	)
Exchange  translation adjustment		(1	)
Balance as of December 31, 2014		964
Reversal during the year		(790	)
Exchange  translation adjustment		(56	)
Balance as of December 31, 2015		118

Deferred tax liabilities arose on the recognition of the identifiable intangible assets acquired from acquisition transactions and deconsolidation of subsidiaries consummated in previous years. Reversal for the years ended December 31, 2015 and 2014 of approximately US$152,000 and approximately US$225,000, respectively, were due to amortization of the acquired intangible assets. Reversal of approximately US$672,000 and US$247,000 for the years ended December 31, 2015 and 2014, respectively, was related to losses recognized for impairment on intangible assets and equity method investments.

The Company’s deferred tax assets at December 31, 2015 and December 31, 2014 were as follows:

	As of December 31,
	2015			2014
	US$(’000)			US$(’000)
Tax effect of net operating losses carried forward		7,921			6,655
Bad debts provision		932			943
Valuation allowance		(7,303	)		(6,385	)
Total deferred tax assets		1,550			1,213

	As of December 31,
	2015		2014
	US$(’000)		US$(’000)
Deferred tax assets reclassified as current asset		-		176
Deferred tax assets reclassified as non-current asset		1,550		1,037
Total deferred tax assets		1,550		1,213

The net operating losses carried forward incurred by the Company (excluding its PRC operating subsidiaries and VIEs) were approximately US$14,903,000 and US$12,161,000 at December 31, 2015 and 2014, respectively, which loss carry forwards gradually expire over time, the last of which expires in 2035. A full valuation allowance has been recorded because it is considered more likely than not that the deferred tax assets will not be realized through sufficient future earnings of the entity to which the operating losses relate.

The net operating losses carried forward (excluding bad debts provision and non-deductible expenses) incurred by the Company’s PRC subsidiaries and VIEs were approximately US$15,657,000 and US$12,401,000 at December 31, 2015 and 2014, respectively, which loss carry forwards gradually expire over time, the last of which expires in 2020. The related deferred tax assets were calculated based on the respective net operating losses incurred by each of the PRC subsidiaries and VIEs and the respective corresponding enacted tax rate that will be in effect in the period in which the losses are expected to be utilized. The Company recorded approximately US$52,000 and US$590,000 net valuation allowance for the years ended December 31, 2015 and 2014, respectively, because it is considered more likely than not that this portion of the deferred tax assets will not be realized through sufficient future earnings of the entities to which the operating losses relate.

Full valuation allowance to bad debts provision related deferred tax assets were recorded because it is considered more likely than not that this portion of deferred tax assets will not be realized through bad debts verification by the local tax authorities where the PRC subsidiaries and VIEs operate in.

The Company’s non-current portion of deferred tax assets and deferred tax liabilities were attributable to different tax-paying components of the entity, which were under different tax jurisdictions. Therefore, in accordance with ASC Topic 740 “Income taxes”, the non-current portion of deferred tax assets and deferred tax liabilities were presented separately in the Company’s balance sheets.

The tax authority of the PRC government conducts periodic and ad hoc tax filing reviews on business enterprises operating in the PRC after those enterprises had completed their relevant tax filings, hence the Company’s tax filings may not be finalized. It is therefore uncertain as to whether the PRC tax authority may take different views about the Company’s tax filings which may lead to additional tax liabilities (See Note 3 (w) for the related provisions in accordance with the PRC Tax Administration and Collection Law).