no.
it can be seen from the statement in article 24 of the enterprise income tax law that "the income tax actually paid by foreign enterprises abroad" that whether it is directly or indirectly controlled, it should be the income tax paid by foreign enterprises abroad, and the income tax withheld and remitted belongs to the income tax paid by foreign enterprises in China, which is not within the scope of credit.
according to the provisions of article 4 of the notice on issues related to tax credit for overseas income of enterprises (caishui [29] No.125), there are several cases in which the tax paid by enterprises abroad cannot be credited:
First, the overseas income tax is wrongly paid or levied according to overseas income tax laws and relevant regulations;
the second is the overseas income tax that should not be levied according to the provisions of the tax treaty;
third, the additional interest, late payment or penalty due to underpayment or late payment of overseas income tax;
fourth, the overseas income tax actually returned or compensated by overseas income tax payers or their interested parties from overseas tax payers;
fifth, according to the provisions of China's enterprise income tax law and its implementing regulations, the overseas income tax that has been exempted from the overseas income burden of China's enterprise income tax; Sixth, the overseas income tax that has been deducted from the overseas taxable income of enterprises in accordance with the relevant regulations of the competent departments of finance and taxation of the State Council. Extended information
According to Article 31 of the Law of the People's Republic of China on the Administration of Tax Collection (as amended at the 14th session of the 12th the NPC Standing Committee), "Taxpayers and withholding agents shall pay or remit tax within the time limit prescribed by laws and administrative regulations or determined by tax authorities in accordance with the provisions of laws and administrative regulations.
If taxpayers are unable to pay taxes on time due to special difficulties, they may postpone the payment of taxes for a maximum of three months with the approval of the State Taxation Bureau and the Local Taxation Bureau of provinces, autonomous regions and municipalities directly under the Central Government. "
Baidu Encyclopedia-Enterprise Income Tax Law of the People's Republic of China