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Income Taxes
12 Months Ended
Dec. 31, 2025
Income Taxes [Abstract]  
INCOME TAXES

18. INCOME TAXES

 

Cayman Islands

 

The Company is incorporated in the Cayman Islands and conducts its primary business operations through the subsidiaries in the PRC and Hong Kong. Under the current laws of the Cayman Islands, the Cayman Islands levies no taxes on individuals or corporations based upon profits, income, gains or appreciation and the Company is therefore not subject to tax on income or capital gains arising in Cayman Islands.

 

British Virgin Islands

 

Subsidiaries British Virgin Islands are not subject to tax on income or capital gains under the current laws of the British Virgin Islands. Additionally, upon payments of dividends by the Company to its shareholders, no British Virgin Islands withholding tax will be imposed.

 

Hong Kong

 

Subsidiaries in Hong Kong are subject to a two-tiered income tax rate for taxable income earned in Hong Kong. The first 2,000 Hong Kong dollars of profits earned by a company is subject to be taxed at an income tax rate of 8.25%, while the remaining profits will continue to be taxed at the existing tax rate of 16.5%. No provision for Hong Kong profits tax has been made in the consolidated financial statements as it has no assessable profit for the years ended December 31, 2024 and 2025.

 

Thailand

 

Subsidiaries in Thailand are subject to corporate income tax on taxable profits earned in Thailand. The standard corporate income tax rate is 20%. For small and medium enterprises (“SMEs”), a progressive tax rate applies: profits not exceeding 300,000 Thai Baht are exempt from tax; profits between 300,001 and 3,000,000 Thai Baht are taxed at 15%; and profits exceeding 3,000,000 Thai Baht are taxed at 20%

 

PRC

 

The Company’s PRC subsidiaries are incorporated in the PRC and subject to the statutory rate of 25% on the taxable income in accordance with the Enterprise Income Tax Law (the “EIT Law”), which was effective since January 1, 2008, except for certain entities eligible for preferential tax rates.

Dividends, interests, rent or royalties payable by the Company’s PRC subsidiaries, to non-PRC resident enterprises, and proceeds from any such non-resident enterprise investor’s disposition of assets (after deducting the net value of such assets) shall be subject to 10% withholding tax, unless the respective non-PRC resident enterprise’s jurisdiction of incorporation has a tax treaty or arrangements with China that provides for a reduced withholding tax rate or an exemption from withholding tax.

 

The EIT Law also provides that enterprises established under the laws of foreign countries or regions and whose “place of effective management” is located within the PRC are considered PRC tax resident enterprises and subject to PRC income tax at the rate of 25% on worldwide income. The definition of “place of effective management” refers to an establishment that exercises, in substance, overall management and control over the production and business, personnel, accounting, properties, etc. of an enterprise.

 

As of December 31, 2025, the administrative practice associated with interpreting and applying the concept of “place of effective management” is unclear. If the Company is deemed as a PRC tax resident, it will be subject to 25% PRC enterprise income tax under the EIT Law on its worldwide income, meanwhile the dividend it receives from another PRC tax resident company will be exempted from 25% PRC income tax. The Company will continue to monitor changes in the interpretation or guidance of this law.

 

Loss before income taxes consisted of:

 

   As of December 31, 
   2024   2025 
   RMB   RMB   US$ 
Non-PRC   (14,742)   (8,058)   (1,146)
PRC   (41,620)   (72,420)   (10,303)
    (56,362)   (80,478)   (11,449)

 

The following table presents the composition of income tax expenses for the years ended December 31, 2024 and 2025:

 

   As of December 31, 
   2024   2025 
   RMB   RMB   US$ 
Current income tax expense   -    3,581    509 
Deferred income tax expense   -    -    - 
    -    3,581    509 

 

The reconciliation of the effective tax rate and the statutory income tax rate applicable to PRC operations was as follow:

 

   As of December 31, 
   2024   2025 
   RMB   RMB   US$ 
Loss before provision for income taxes   (56,362)   (80,478)   (11,449)
Income tax benefit computed at an applicable tax rate of 25%   (14,091)   (20,120)   (2,862)
The effect of different tax rate   659    302    43 
Change in valuation allowance   13,432    23,399    3,328 
    
-
    3,581    509 

Deferred Taxes

 

Deferred income taxes reflect the net tax effects of temporary differences between the carrying amount of assets and liabilities for financial reporting purposes and the amounts used for income tax purposes. Significant components of the Group’s deferred tax assets and deferred tax liabilities were as follows:

 

 

    As of December 31,  
    2024     2025  
    RMB     RMB     US$  
Deferred tax assets:                        
Current and prior year tax losses       45,483       69,010       9,818  
Allowance for credit loss     -       230       33  
Total deferred tax assets     45,483       69,240       9,851  
Less: valuation allowance     (45,483 )     (69,240 )     (9,851 )
Deferred tax assets, net     -       -       -  

  

Realization of the net deferred tax assets is dependent on factors including future reversals of existing taxable temporary differences and adequate future taxable income, exclusive of reversing deductible temporary differences and tax loss carry forwards. The Group evaluates the potential realization of deferred tax assets on an entity-by-entity basis.

 

As of December 31, 2024 and 2025, valuation allowances were mainly provided against deferred tax assets caused by net operating losses carried forward in entities where it was determined that it was more likely than not that the benefits of the deferred tax assets will not be realized due to their recurring losses.

 

According to PRC tax regulations, the PRC net operating loss can generally carry forward for no longer than five years starting from the year subsequent to the year in which the loss was incurred. Carryback of losses is not permitted.

 

As of December 31, 2025, net operating tax loss carry forwards in PRC is expected to expire as follows:

 

   As of December 31, 2025 
   RMB   US$ 
2026   11,465    1,631 
2027   39,695    5,647 
2028   26,870    3,823 
2029   62,872    8,945 
2030   111,121    15,809 
    252,023    35,855 

 

Uncertain tax positions

 

The Group evaluates each uncertain tax position (including the potential application of interest and penalties) based on the technical merits, and measure the unrecognized benefits associated with the tax positions. As of December 31, 2024 and 2025, the Group did not have any significant unrecognized uncertain tax positions.

 

The Group did not accrue any liability, interest or penalties related to uncertain tax positions in its provision for income taxes line of its consolidated statements of operations for the years ended December 31, 2024 and 2025.