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Taxation
12 Months Ended
Dec. 31, 2022
Major components of tax expense (income) [abstract]  
Taxation
10.
Taxation
(a)
Income tax expense

Income tax expense is recognized based on management’s best knowledge of the income tax rates expected for the financial year.

(i)
Cayman Islands

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

(ii)
Hong Kong

Under the current tax laws of Hong Kong, TME Hong Kong is subject to Hong Kong profits tax at 16.5% on its taxable income generated from the operations in Hong Kong. Dividends from TME Hong Kong is not subject to Hong Kong profits tax.

(iii)
PRC

Under the Corporate Income Tax (“CIT”) Law in the PRC, foreign invested enterprises and domestic enterprises are subject to a unified CIT rate of 25%, except for available preferential tax treatments, including tax concession for enterprise approved as “High and New Technology Enterprise” (“HNTE”) and “Software Enterprise” (“SE”), and enterprise established in certain special economic development zones. Qualified HNTE is eligible for a preferential tax rate of 15%, Qualified SE is entitled to an exemption from income tax for the first two years, commencing from the first profitable year, and a reduction of half tax rate for the next three years.

Beijing Kuwo and a subsidiary of the Group, Guangzhou Fanxing Entertainment Information Technology Co., Ltd. (“Fanxing”), have been recognized as HNTE by relevant government authorities and were entitled to a preferential tax rate of 15% for the years ended December 31, 2020, 2021 and 2022. Guangzhou Kugou has also been recognized as HNTE by the relevant government authorities and was entitled to a preferential tax rate of 15% for the years ended December 31, 2020 and subject to the unified CIT rate of 25% for the year ended December 31, 2021 and 2022. For the years ended December 31, 2020 and 2021, Yeelion Online and TME Tech Shenzhen were entitled to a reduced tax rate of 12.5%. For the year ended December 31, 2022, Yeelion Online and TME Tech Shenzhen were recognized as HNTE by relevant government authorities and were entitled to a preferential tax rate of 15%. Yeelion Online Network Technology (Tianjin) Co., Ltd. (“Yeelion Online Tianjin”) and Guangzhou Shiyinlian Software Technology Co., Ltd. (“Shiyinlian”) were qualified as SE and have been entitled to tax holidays for the year ended December 31, 2020 (i.e. their first profitable year in 2019), and they were entitled to a reduced tax rate of 12.5% for the years ended December 31, 2021 and 2022.

Certain subsidiaries of the Group are entitled to other tax concession, mainly include the preferential tax rate of 15% applicable to some subsidiaries located in certain area of PRC upon fulfillment of certain requirements of the respective local government.

Furthermore, certain subsidiaries of the Group are subject to other preferential tax treatment for certain reduced tax rates ranging from 2.5% to 9%.

The income tax expense of the Group is analyzed as follows:

 

 

Year ended December 31,

 

 

2020

 

 

2021

 

 

2022

 

 

RMB’million

 

 

RMB’million

 

 

RMB’million

 

Current income tax

 

 

634

 

 

 

530

 

 

 

604

 

Deferred income tax (note b)

 

 

(178

)

 

 

(113

)

 

 

(70

)

Total income tax expense

 

 

456

 

 

 

417

 

 

 

534

 

 

The taxation on the Group’s profit before income tax differs from the theoretical amount that would arise using the tax rate of 25% for the years ended December 31, 2020, 2021 and 2022, being the tax rate of the major subsidiaries of the Group before enjoying preferential tax treatments, as follows:

 

 

Year ended December 31,

 

 

2020

 

 

2021

 

 

2022

 

 

 

RMB’million

 

 

RMB’million

 

 

RMB’million

 

Profit before income tax

 

 

4,632

 

 

 

3,632

 

 

 

4,373

 

Tax calculated at a tax rate of 25%

 

 

1,158

 

 

 

908

 

 

 

1,093

 

Effects of different tax rates applicable to different subsidiaries of the Group

 

 

34

 

 

 

29

 

 

 

(22

)

Effects of tax holiday on assessable profit of certain subsidiaries

 

 

(214

)

 

 

(34

)

 

-

 

Effects of preferential tax rate on assessable profit of certain subsidiaries

 

 

(631

)

 

 

(664

)

 

 

(764

)

Expense not deductible for tax purposes

 

 

82

 

 

 

191

 

 

 

222

 

Income not subject to tax

 

 

-

 

 

 

(3

)

 

-

 

Unrecognized deferred income tax assets

 

 

46

 

 

 

27

 

 

 

44

 

Utilization of previously unrecognized tax assets

 

 

(11

)

 

 

(38

)

 

 

(33

)

Others

 

 

(8

)

 

 

1

 

 

 

(6

)

 

 

456

 

 

 

417

 

 

 

534

 

 

The aggregate amount and per share effect of the tax holiday are as follows:

 

 

Year ended December 31,

 

2020

 

 

2021

 

 

2022

 

 

RMB’million

 

 

RMB’million

 

 

RMB’million

Effects of tax holiday on assessable profit of certain subsidiaries

 

 

214

 

 

 

34

 

 

-

Per ordinary share effect—basic

 

 

0.06

 

 

 

0.01

 

 

-

Per ordinary share effect—diluted

 

 

0.06

 

 

 

0.01

 

 

-

 

The Group’s profit before tax consists of:

 

 

Year ended December 31,

 

 

2020
RMB’million

 

 

2021
RMB’million

 

 

2022
RMB’million

 

Non-PRC

 

 

(4

)

 

 

(5

)

 

 

219

 

PRC

 

 

4,636

 

 

 

3,637

 

 

 

4,154

 

 

 

4,632

 

 

 

3,632

 

 

 

4,373

 

 

(b)
Deferred income tax

 

 

As at December 31,

 

 

2021

 

 

2022

 

 

RMB’million

 

 

RMB’million

 

The deferred tax assets comprise temporary differences attributable to:

 

 

 

 

 

 

Prepayments

 

 

134

 

 

 

134

 

Deferred revenue

 

 

83

 

 

 

49

 

Accruals

 

 

118

 

 

 

159

 

Others

 

 

15

 

 

 

9

 

Total deferred tax assets

 

 

350

 

 

 

351

 

Set-off of deferred tax liabilities pursuant to set-off provisions

 

 

(4

)

 

 

(4

)

Net deferred tax assets

 

 

346

 

 

 

347

 

The deferred tax liabilities comprise temporary differences attributable to:

 

 

 

 

 

 

Intangible assets acquired in business combinations

 

 

275

 

 

 

215

 

Total deferred tax liabilities

 

 

275

 

 

 

215

 

Set-off of deferred tax liabilities pursuant to set-off provisions

 

 

(4

)

 

 

(4

)

Net deferred liabilities

 

 

271

 

 

 

211

 

 

The recovery of deferred income tax:

 

 

As at December 31,

 

 

2021

 

 

2022

 

 

RMB’million

 

 

RMB’million

 

Deferred tax assets:

 

 

 

 

 

 

to be recovered after more than 12 months

 

 

48

 

 

 

12

 

to be recovered within 12 months

 

 

298

 

 

 

335

 

 

 

346

 

 

 

347

 

Deferred tax liabilities:

 

 

 

 

 

 

to be recovered after more than 12 months

 

 

201

 

 

 

152

 

to be recovered within 12 months

 

 

70

 

 

 

59

 

 

 

271

 

 

 

211

 

 

The movements of deferred income tax assets were as follows:

 

 

Prepayment
and other
investments

 

 

Deferred
revenue

 

 

Accruals

 

 

Others

 

 

Total

 

 

 

RMB’million

 

 

RMB’million

 

 

RMB’million

 

 

RMB’million

 

 

RMB’million

 

At January 1, 2021

 

 

105

 

 

 

55

 

 

 

136

 

 

 

12

 

 

 

308

 

Credited/(charged) to income statement

 

 

29

 

 

 

28

 

 

 

(18

)

 

 

3

 

 

 

42

 

At December 31, 2021

 

 

134

 

 

 

83

 

 

 

118

 

 

 

15

 

 

 

350

 

(Charged)/credited to income statement

 

-

 

 

 

(34

)

 

 

41

 

 

 

(6

)

 

 

1

 

At December 31, 2022

 

 

134

 

 

 

49

 

 

 

159

 

 

 

9

 

 

 

351

 

 

The Group only recognizes deferred income tax assets for cumulative tax losses if it is probable that future taxable amounts will be available to utilize those tax losses. Management will continue to assess the recognition of deferred income tax assets in future reporting periods. As at December 31, 2021 and 2022, the Group did not recognize deferred income tax assets of RMB130 million and RMB136 million respectively in respect of cumulative tax losses amounting to RMB674 million and RMB671 million respectively. These tax losses will expire from 2023 to 2027.

The movements of deferred income tax liabilities were as follows:

 

 

Intangible
assets

 

 

RMB’million

 

At January 1, 2021

 

 

270

 

Credited to income statement

 

 

(71

)

Business combinations

 

 

76

 

At December 31, 2021

 

 

275

 

Credited to income statement

 

 

(69

)

Business combinations

 

 

9

 

At December 31, 2022

 

 

215