Circular on Issues Relevant to the Implementation of Articles on Royalties of Tax Agreements
The Circular clarifies the amounts or remuneration that shall not be treated as royalties but rather as income derived from service activities.
CLP Reference: 3230/09.09.14
PRC Reference: 国税函  507号
Promulgated: 14 September 2009
Effective: 01 October 2009
Keywords (click to search):
avoidance of double taxation
(Issued by the State Administration of Taxation on September 14 2009 and effective as of October 1 2009.)
Guo Shui Han  No.507
Offices of the State Administration of Taxation and local taxation bureaux of provinces, autonomous regions, municipalities directly under the central government and cities with independent development plans and Yangzhou Tax Institute:
Pursuant to relevant provisions of agreements on the avoidance of double taxation entered into by the government of the People’s Republic of China with foreign governments (including the tax arrangements entered into by mainland China with Hong Kong and Macao Special Administrative Regions; hereinafter collectively referred to as Tax Agreements), we hereby notify you on issues relevant to the implementation of articles on royalties of Tax Agreements as follows:
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