China issues additional clarifying guidance on permanent establishment issues related to secondment arrangements [TAX ALERT]

July 29, 2013

Pursuant to the Corporate Income Tax (CIT) Law and its detailed implementation rules, income tax treaties (treaties) between China and other countries/regions (including Hong Kong and Macao), and Guoshuifa [2010] No. 75 (Circular 75)1, the State Administration of Taxation (SAT) released SAT Announcement [2013] No. 19 (Announcement 19) on 19 April 2013, that clarifies certain issues related to CIT collection on services provided by nonresident companies to Chinese companies under labor dispatch arrangements.

The main points of Announcement 19 are summarized below.

Further details are available from the Ernst & Young Tax Alert which can be accessed using the link below:

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