A recent notice provides clarity on what activities of a Permanent Establishment are subject to taxation. This should prompt foreign businesses to re-evaluate their set-up structure
When an enterprise derives revenue from the transfer of property, etc., it shall include all of the revenue in the year that is recognised to be the year in which such revenue is derived.
It's been a busy year for tax authorities in 2010 and next year will be no different. Foreign companies are no longer privy to preferential tax treatments and non-resident enterprises can expect tightening on indirect equity transfers, treaty benefits and transfer pricing audits