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Income Taxes
6 Months Ended
Dec. 31, 2024
Income Tax Disclosure [Abstract]  
Income Taxes

7. Income Taxes

 

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

 

British Virgin Islands (“BVI”)

 

Under the current laws of the BVI, the Group’s subsidiaries incorporated in BVI are not subject to tax on income or capital gains. Additionally, upon payments of dividends by these BVI companies to its respective shareholders, no BVI withholding tax will be imposed.

 

Hong Kong, PRC

 

Our subsidiary, HK 3e Network, is a Hong Kong entity subject to the two-tier profits tax rates system, which was introduced under the Inland Revenue (Amendment) (No.3) Ordinance 2018 (the “Ordinance”) of Hong Kong, and applies for a year of assessment commencing on or after 1 April 2018.

 

Under the two-tier profit tax rates regime, the profits tax rate for the first HKD 2 million of assessable profits of a corporation will be subject to the lowered tax rate of 8.25% while the remaining assessable profits will be subject to the tax rate of 16.5%.

 

In respect of dividends paid to HK 3e Network by Guangzhou 3e Network and Guangzhou Sanyi Network, under Hong Kong’s Foreign-sourced Income Exemption regime effective from 1 January 2023, income arising in or derived from a territory outside Hong Kong (such as dividends) received by a Hong Kong entity which is a multinational enterprise entity (“MNE entity”) carrying on business in Hong Kong may be regarded as specified foreign-sourced income which will be deemed to be sourced from Hong Kong and chargeable to profits tax, subject to certain exemptions. In addition, payments of dividends from our Hong Kong subsidiary to its shareholder(s) are not subject to any Hong Kong withholding tax.

 

Mainland, PRC

 

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

 

For the six months ended December 31, 2024 and 2023, the income tax rate of the Group’s PRC subsidiaries is 25%.

 

   For the six months ended
December 31
 
   2024   2023 
   US$   US$ 
Current tax expense   132,142    25,228 
Deferred tax expense   65,626    91,275 
Income tax expenses   197,768    116,503 

A reconciliation of the income tax expense determined at the PRC statutory income tax rate to the Group’s actual income tax expense is as follows:

 

   For the six months ended
December 31,
 
   2024   2023 
   US$   US$ 
Income before income tax expense   1,267,095    800,896 
PRC statutory income tax rate   25%   25%
Income tax at PRC statutory income tax rate   316,774    200,224 
Difference due to preferential tax   (94,614)   (53,863)
Super deduction of qualified R&D expenditures   (37,446)   (29,859)
Non-deductible items   110     
Utilization of tax loss carried forward   (61,887)   (91,275)
Realization of deferred tax assets   74,831    91,275 
Income tax expense   197,768    116,503 

 

The Group’s deferred tax assets at December 31, 2024 and June 30, 2024 were as follows:

 

   As of
December 31,
2024
   As of
June 30,
2024
 
   US$   US$ 
Deferred tax assets   39,872    104,857 
Less, valuation allowance        
Deferred tax assets, net   39,872    104,857 

 

Deferred tax assets represented net operating losses (NOLs) carryforward and accrued credit losses expense. Total NOLs carryforwards of the Group’s subsidiary in mainland China is RMB989,572 and RMB2,708,625 as of December 31, 2024 and June 30, 2024, respectively. As of December 31, 2024, nil NOL would expire by 2024 if not utilized. For the six months ended December 31, 2024 and 2023, deferred tax assets from accrued credit losses expense were RMB43,644 and nil, respectively.

 

For the six months ended December 31, 2024 and 2023, the Group did not have any material interest or penalties associated with tax positions. The Group did not have any significant unrecognized uncertain tax positions as of December 31, 2024 or June 30, 2024. The Group does not expect that its assessment regarding unrecognized tax positions will materially change over the next 12 months.