State Administration of Taxation, Circular on Issues Relevant to the Implementation of Articles on Royalties of Tax Agreements

国家税务总局关于执行税收协定特许权使用费条款有关问题的通知

December 08, 2009 | BY

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Three types of items not treated as royalties.

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Issued: September 14 2009

Effective: October 1 2009

Main contents: The following amounts or remuneration shall not be treated as royalties but rather as income derived from service activities:

(1) remuneration for after-sales services under a straightforward merchandise trading arrangement;

(2) remuneration derived by the seller from the provision of services