The new policy of Cai Shui 2022 Notice No. 3 is a major institutional innovation for infrastructure REITs in China, which greatly benefits the supply of REITs products and market development. Huazheng tax experts analyze the full tax treatment of the five major aspects of infrastructure REITs structure building under the new policy and propose operational considerations with service cases and research results. To support the pilot real estate investment funds in the infrastructure sector (referred to as infrastructure REITs), on 26 January 2022, the Ministry of Finance and the State Administration of Taxation (SAT) issued the Announcement on Taxation Policies for Real Estate Investment Trusts in the Infrastructure Sector (REITs) Pilot (Announcement No. 3 of 2022, hereinafter referred to as Announcement No. 3), which stipulates that from 1 January 2021 onwards, the original equity the transfer of infrastructure assets by the original equity holders to the project company and the transfer of equity interests in the project company by the original equity holders to the infrastructure REITs shall be subject to the special tax treatment for enterprise income tax.