Official Reply on Issues of Determining What Constitutes a Permanent Establishment of a Foreign Enterprise Providing Services in China and of the Attribution of the Profits Derived Thereby

关于外国企业在中国境内提供劳务活动常设机构判定及利润归属问题的批复

The Official Reply addresses queries from Provisional Office of the State Administration of Taxation on the definition of permanent establishments of foreign enterprise providing services in the PRC.

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(Issued by the State Administration of Taxation on July 19 2006.):

(国家税务总局于二零零六年七月十九日发布。)

Guo Shui Han [2006] No.694

国税函 [2006] 694号