Is it necessary for a family company to pay enterprise income tax for its 100% subsidiary?

Family company 100% holding subsidiary, the subsidiary does not need to pay enterprise income tax. According to relevant public information, the parent company transferred the real estate and land to the subsidiary holding 100% for free. Those who meet the requirements stipulated in Caishui [20 14] 109 can choose to be treated with special tax treatment and be exempted from enterprise income tax.