Circular on Issues Relevant to the Implementation of Articles on Royalties of Tax Agreements

关于执行税收协定特许权使用费条款有关问题的通知

The Circular clarifies the amounts or remuneration that shall not be treated as royalties but rather as income derived from service activities.

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

(国家税务总局于二零零九年九月十四日发布，自二零零九年十月一日起执行。)

Guo Shui Han [2009] No.507

国税函 [2009] 507号

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