China Law & Practice

Follow us:

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 [2009] 507号

Promulgated: 14 September 2009

Effective: 01 October 2009

Keywords (click to search): royalties tax agreements tax conventions avoidance of double taxation proprietary technology

(Issued by the State Administration of Taxation on September 14 2009 and effective as of October 1 2009.)


Guo Shui Han [2009] No.507

国税函 [2009] 507号

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:


Register with China Law & Practice to unlock our premium content for the next 14 days.

**Full text translations are only available for individual purchase or as part of a subscription.