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TAXATION
 12 Months Ended
Dec. 31, 2025
TAXATION  
TAXATION

15.TAXATION

(a)Enterprise income tax (“EIT”)

Cayman Islands

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

Singapore

Under the current laws of Singapore, the subsidiaries incorporated in Singapore are subject to the prevailing Singapore Corporate Tax of 17%.

Malaysia

Under the current laws of Malaysia, the subsidiaries incorporated in Malaysia are subject to the Malaysia Cooperate Income Tax of 24%.

The United States of America (“U.S.”)

Under the current laws of the U.S., the subsidiaries incorporated in the U.S. are subject to U.S. Federal Income Tax of 21%, and State Income Tax of 6.5% to 8.84%.

PRC

Under the PRC Enterprise Income Tax Law (the “EIT Law”), the standard enterprise income tax rate for domestic enterprises and foreign invested enterprises is 25%.

According to the circular of “Continuing to Implement Preferential Enterprise Income Tax Policies for Western Development”(Ministry of Finance announcement [2020] No. 23) issued by the Ministry of Finance, the State Administration of Taxation and the National Development and Reform Commission and relevant PRC enterprise income tax regulations, entities that are qualified and located in certain western provinces of mainland China are entitled to a preferential enterprise income tax rate of 15%. Certain entities of the Group that are engaged in the “Encouraged Industries in the Western Region” stated in the Ministry of Finance announcement [2020] No. 23 are eligible for the preferential EIT rate at 15%.

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 cost base 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.

15.TAXATION (CONTINUED)

(a)Enterprise income tax (“EIT”) (continued)

The following table sets forth the component of profit before income tax expenses of the Group for the year ended December 31, 2025.

​

​

​

​

​

  ​ ​ ​

For the Years Ended

​

​

 December 31,

​

​

2025

​

​

RMB

PRC

 

2,214,170

Others

 

(596,084)

​

 

1,618,086

​

The following table sets forth the component of enterprise income tax expenses of the Group for the years ended December 31, 2023, 2024 and 2025.

​

​

​

​

​

​

​

​

For the Years Ended December 31, 

​

​

2023

​

2024

​

  ​ ​ ​

RMB

  ​ ​ ​

RMB

Current income tax expense

 

299,533

 

654,380

Deferred income tax benefit

 

(95,772)

 

(126,873)

Income tax expense

 

203,761

 

527,507

​

​

​

​

​

  ​ ​ ​

For the Year Ended 

​

​

December 31,

​

​

2025

​

​

RMB

Current income tax expense

​

  ​

- PRC

 

560,956

- Others

 

20,396

Deferred income tax benefit

 

  ​

- PRC

 

(52,791)

- Others

 

(96,820)

Income tax expense

 

431,741

​

For the year ended December 31, 2025, total income tax paid in the PRC was RMB604.1 million, and total income tax paid in other jurisdictions was RMB26.1 million.

15.TAXATION (CONTINUED)

(a)Enterprise income tax (“EIT”) (continued)

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

​

​

​

​

​

​

​

​

For the Years Ended December 31, 

​

  ​ ​ ​

2023

​

2024

​

​

%

​

%

PRC statutory income tax rate

​

25.00

​

25.00

Effect of tax rate differential in other jurisdictions

 

—

​

0.47

Tax effect of preferential tax treatments

 

(6.80)

​

(9.55)

Tax effect of permanent differences

 

2.05

​

0.16

Changes in valuation allowance

 

—

​

1.26

Effective income tax rate

 

20.25

​

17.34

​

​

​

​

​

​

​

​

For the Year Ended December 31, 2025

​

​

Amount

​

Percent

​

  ​ ​ ​

RMB

  ​ ​ ​

%

PRC statutory income tax rate

  ​ ​ ​

404,521

  ​ ​ ​

25.00

Tax effect of PRC preferential tax treatments

​

(293,247)

​

(18.12)

Tax effect of permanent differences

​

​

​

​

Share-based compensation expenses

​

161,128

​

9.96

Others

​

18,999

​

1.17

Changes in valuation allowance

​

53,803

​

3.33

Foreign tax effects

​

  ​

​

  ​

the U.S.

​

​

​

​

Effect of tax rate differential in other jurisdictions

​

(13,129)

​

(0.81)

Non-deductible expenses

​

7,308

​

0.45

Changes in valuation allowance

​

71,520

​

4.42

Singapore

​

​

​

​

Effect of tax rate differential in other jurisdictions

​

25,131

​

1.55

Non-deductible expenses

​

20,122

​

1.24

Changes in valuation allowance

​

(24,008)

​

(1.48)

Other tax jurisdictions

​

(407)

​

(0.03)

Effective income tax rate

​

431,741

​

26.68

​

​

15.TAXATION (CONTINUED)

(b)Deferred Taxes

The significant components of deferred taxes are as follows:

​

​

​

​

​

​

​

​

As of December 31, 

​

​

2024

​

2025

​

  ​ ​ ​

RMB

  ​ ​ ​

RMB

Deferred tax assets:

​

​

​

​

Contract liabilities

 

43,794

 

46,691

Net operating tax losses carried forward

 

126,368

 

353,148

Accrued expenses

 

15,968

 

18,166

Advertising expenses in excess of deduction limit

 

102,621

 

125,605

Expected credit loss

 

1,548

 

2,291

Lease liabilities

 

127,026

 

272,614

Others

 

—

 

5,567

Subtotal

 

417,325

 

824,082

Less: valuation allowance

 

(38,201)

 

(142,520)

Less: deferred tax liabilities in relation to property and equipment-(accelerated depreciation)

​

—

​

(5,957)

Less: deferred tax liabilities in relation to right-of-use asset

 

(125,914)

 

(272,784)

Total deferred tax assets, net

 

253,210

 

402,821

​

The following table presents the movement of the valuation allowance for the deferred tax assets:

​

​

​

​

​

​

​

​

​

​

For the Years Ended December 31,

​

  ​ ​ ​

2023

  ​ ​ ​

2024

​

2025

​

​

RMB

​

RMB

​

RMB

​

​

​

​

​

​

​

Balance at the beginning of the year

 

—

 

—

 

38,201

Increase during the year

 

—

 

38,201

 

104,319

Balance at the end of the year

 

—

 

38,201

 

142,520

​

The tax losses of the Group expire over different time intervals depending on the local jurisdiction. As of December 31, 2025, total net operating tax losses carried forward of the Group, if not utilized, will expire as follows:

​

​

​

​

​

  ​ ​ ​

RMB

Loss expiring for the year ending December 31, 2026

​

5,582

Loss expiring for the year ending December 31, 2027

 

6,986

Loss expiring for the year ending December 31, 2028

 

46,884

Loss expiring for the year ending December 31, 2029

 

276,462

Loss expiring for the year ending December 31, 2030

 

472,413

Thereafter

 

662,970

Subtotal

 

1,471,297

​

​

15.TAXATION (CONTINUED)

(b)Deferred Taxes (continued)

In addition, according to the EIT Law and its implementation rules, foreign enterprises, which have no establishment or place in the PRC but derive dividends, interest, rents, royalties and capital gains from sources in the PRC shall be subject to PRC withholding tax (“WHT”) at 10% (a further reduced WHT rate may be available according to the applicable double tax treaty or arrangement). The 10% WHT is applicable to any dividends to be distributed from the Group’s PRC subsidiaries to the Group’s overseas companies unless otherwise reduced pursuant to applicable tax treaties or tax arrangements between the PRC government and the government of other jurisdiction. Although there are undistributed earnings of the Company’s subsidiaries in the PRC that are available for distribution to the Company, the undistributed earnings of the Company’s subsidiaries located in the PRC are to be indefinitely reinvested for use in the operation and expansion of its business. Accordingly, no deferred income tax liability has been accrued for the PRC dividend withholding taxes that would be payable upon the distribution of those amounts to the Company as of December 31, 2024 and 2025. The undistributed earnings from the Company’s subsidiaries in the PRC as of December 31, 2024 and 2025 were RMB4,025.85 million and RMB6,231.28 million, respectively. An estimated withholding tax of RMB402.59 million and RMB623.13 million would be due if these earnings were remitted as dividends as of December 31, 2024 and 2025, respectively.

The major jurisdictions in which the Group are subject to potential examination are the PRC, the U.S. and Singapore.

According to the PRC Tax Administration and Collection Law, the statute of limitation is three years if the underpayment of taxes is due to computational errors made by the taxpayer or the withholding agent. The statute of limitation is extended to five years under special circumstances where the underpayment of taxes is more than RMB100 thousand. In the case of transfer pricing issues, the statute of limitation is 10 years. There is no statute of limitation in the case of tax evasion.

According to the U.S. Internal Revenue Code, the statute of limitation is three years in general. The statute of limitation is extended to six years under certain circumstances involving substantial understatement of income. There is no statute of limitation in the case of tax fraud or willful tax evasion.

Under Singapore Income Tax Act, the statute of limitation is four years in general, with no statute of limitation in the case of tax fraud or willful default.

Accordingly, the income tax returns of the Company’s PRC subsidiaries for the years starting from 2020, for its U.S. subsidiaries for 2023 and after, and for its Singapore subsidiaries for 2023 and after, remain open to examination by the respective tax authorities.