Taxation

12 Months Ended

Dec. 31, 2024

Taxation

Taxation

10.

Taxation

Composition of income tax

The following table presents the composition of income tax

expense/(benefit)

for the years ended December 31, 2022, 2023 and 2024:


	For the Year Ended December 31,
	2022			2023			2024
	RMB in thousands
Current income tax expenses		122,451			81,797			55,738
Withholding income tax expenses		18,189			22,284			17,836
Deferred tax benefits		(36,495	)		(25,376	)		(110,118	)

Total		104,145			78,705			(36,544	)

a)	Income taxes

Cayman Islands

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

British Virgin Islands (“BVI”)

Subsidiaries in the BVI are exempted from income tax on their foreign-derived income in the BVI. There are no withholding taxes in the BVI.

Hong Kong, China

Hong Kong profits tax has been provided for at half the current tax rate (i.e., 8.25%) for the first HK$2 million on the estimated assessable profits while the remaining profits will continue to be taxed at the existing 16.5% tax rate for the years ended December 31, 2022, 2023 and 2024, respectively.

Mainland, China

The Enterprise Income Tax (“EIT Law”), which became effective on January 1, 2008, applies a uniform enterprise income tax (“EIT”) rate of 25% to both foreign-invested enterprises (“FIEs”) and domestic companies. Preferential tax treatments will be granted to FIEs or domestic companies which conduct businesses in certain encouraged sectors and to entities otherwise classified as “Software Enterprises”, “Key Software Enterprises”, “Encouraged Enterprises” and/or “High and New Technology Enterprises” (“HNTEs”).

The aforementioned preferential tax rates are subject to annual review by the relevant tax authorities in China. Certain subsidiaries were qualified as HNTEs or Encouraged Enterprises and enjoyed a preferential income tax rate at 15% for the corresponding years from the year they are qualified, respectively, provided that they continue to qualify as HNTEs or Encouraged Enterprises during such periods.

The following table presents a reconciliation of the differences between the statutory income tax rate and the Group’s effective income tax rate for the years ended December 31, 2022, 2023 and 2024:


	For the Year Ended December 31,
	2022			2023			2024
	%			%			%
Statutory income tax rate		25.00			25.00			25.00
Permanent differences		6.74			(1.33	)		5.30
Tax rate difference from statutory rate in other jurisdictions*		(3.19	)		(2.96	)		(7.80	)
Tax effect of preferential tax treatments		(8.91	)		(4.73	)		(9.49	)
Withholding tax		(0.25	)		(0.47	)		(1.29	)
Change in valuation allowance		(20.79	)		(17.17	)		(9.11	)

Effective income tax rate		(1.40	)		(1.66	)		2.61

*	It is primarily due to the tax effect of the Company as a tax-exempt entity incorporated in Hong Kong and the Cayman Islands.

As of December 31, 2024, certain entities of the Group had net operating tax loss carry forwards as follows:


	RMB in thousands
Loss expiring in 2025		138,823
Loss expiring in 2026		482,108
Loss expiring in 2027		878,056
Loss expiring in 2028		896,797
Loss expiring in 2029 and thereafter		18,486,822

Total		20,882,606

Sales tax

The Group’s majority of subsidiaries and VIEs incorporated in China are subject to value added tax (“VAT”) for services rendered at a rate of 6% and for goods sold mainly at a rate of 13%, offset by VAT on purchases. All entities in China are also subject to surcharges on value-added tax payments in accordance with PRC law. In addition, the Group’s advertising revenues are also subject to culture business construction fee at a rate of 3%, which was reduced to 1.5% since July 1, 2019, valid until December 31, 2027.

c)	Deferred tax assets and liabilities

The following table presents the tax impact of significant temporary differences that give rise to the deferred tax assets and liabilities as of December 31, 2023 and 2024:


	December 31, 2023			December 31, 2024
	RMB in thousands
Deferred tax assets:
Deferred revenue		280,872			265,876
Net operating tax loss carry forwards		3,542,650			3,490,177
Accruals and others*		667,180			940,900

Total deferred tax assets		4,490,702			4,696,953

Less: valuation allowance		(4,444,111	)		(4,561,822	)

Net deferred tax assets		46,591			135,131

Deferred tax liabilities
Acquired intangible assets		(88,547	)		(66,969	)

Total deferred tax liabilities		(88,547	)		(66,969	)

*	Accrued and others primary represent accrued expenses which are not deductible until paid under PRC laws, as well as non-deductible advertising expenses.

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 or credit carry forwards. The Group evaluates the potential realization of deferred tax assets on an

entity-by-entity

basis. As of December 31, 2023 and 2024, valuation allowances were provided against deferred tax assets in entities where it was determined it was

more-likely-than-not

that the benefits of the deferred tax assets will not be realized.

The following table sets forth the movement of the aggregate valuation allowances for deferred tax assets for the periods presented:


	Balance at January 1			Re-measurement due to applicable preferential tax rate for HNTE			Addition			Expiration of loss carry forward and impact of disposal/close of subsidiaries		Balance at December 31
2022		(2,122,077	)		—			(1,543,301	)		7,911		(3,657,467	)
2023		(3,657,467	)		(18,437	)		(822,414	)		54,207		(4,444,111	)
2024		(4,444,111	)		—			(129,769	)		12,058		(4,561,822	)

d)	Withholding income tax on dividends

The EIT Law also imposes a withholding income tax of 10% on dividends distributed by a 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 was 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 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.

To the extent that subsidiaries and VIEs of the Group have undistributed earnings, the Group will accrue appropriate expected withholding tax associated with repatriation of such undistributed earnings. As of December 31, 2023 and 2024, the Group did not record any withholding tax on the retained earnings of its subsidiaries and VIEs in the PRC as most of which were still in accumulated deficit position.