Reply of the State Administration of Taxation on the Issue of Revenue Recognition Time for Baoshan Iron and Steel Co., Ltd.'s Packaged Asset Sale

This document provides a tax ruling on the timing of revenue recognition for Baoshan Iron and Steel Co., Ltd.'s transfer of assets to Baosteel Group, applying the asset acquisition restructuring provisions under Caishui [2009] No. 59 and confirming that revenue should be recognized upon the effective date of the transfer agreement and completion of actual asset delivery.