Can the decoration fee of the property be deducted before tax?

Q: A real estate development company renovated the property and handed it over to the property company for use. Is the decoration fee included in the "development cost" or "operating expenses", and can it be deducted before tax? Answer: Article 15 of the Notice of the State Taxation Bureau of People's Republic of China (PRC) on Printing and Distributing the Measures for Handling Enterprise Income Tax on Real Estate Development Business (Guo Shui Fa [2009] No.31) stipulates that an enterprise shall carry out routine maintenance on the unsold completed development products and sold development products (including used parts and facilities and equipment) in accordance with relevant laws, regulations or contracts. Article 17 stipulates that clubs, property management places, power stations, heating stations, water plants, cultural and sports venues, kindergartens and other supporting facilities. The construction of enterprises in the Development Zone shall be handled in accordance with the following provisions: (1) If the property rights are not for profit and belong to all owners or donated to local governments and public utilities free of charge, they can be regarded as public supporting facilities, and their construction costs shall be handled in accordance with the relevant provisions on the fees for public supporting facilities. (2) For the purpose of making profits, or the property right belongs to the enterprise, or the ownership of the property right is unclear, or donated to other units other than local governments and public utilities without compensation, the cost shall be accounted separately. Except for the self-use of enterprises, they are treated as fixed assets, and others are treated as product construction and development. Article 27 stipulates that the taxable cost of developing products is as follows: (5) Expenditure on public supporting facilities: refers to the expenditure on public supporting facilities that are independent, not for profit, owned by all owners, or donated to local governments and government utilities free of charge. According to the above provisions, if the property is non-profit and the property rights belong to all owners, the renovation expenses incurred before the property transfer belong to public facilities and should be included in the development cost; The renovation expenses incurred after the delivery of the property right house to the property company have nothing to do with income, and should be included in the "non-operating expenses" subject. However, if the property right house must be renovated according to laws, regulations or contract provisions, it should be included in the "non-operating expenses" subject, which can be deducted before tax.