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Administration on Tax Treaty Benefits. Anti-avoidance - Cross-border Transactions with Affiliate Companies. Rock graduated from Law School of Peking University, obtained bachelor and master degree of law. In his professional life, Rock has gained extensive knowledge and experiences in China business and tax advisory services for clients in various industries, including securities company, car financing company, advertising company, energy company, real estate company, IT company, etc.
In particular , he is a tax advisor with strategic insights on double tax treaties, non-resident administration, international tax policies. If you need any assistance in purchasing the guideline or have any questions e. In the context of double tax treaties, the term "permanent establishment" is generally adopted.
There is no major difference between the meaning of the two terms but the term "permanent establishment" is more emphasizing the duration of the establishment. Follow us on LinkedIn. Register Login. Description Multimedia Events Exhibitions.
To understand the impact of the new FIL, some history is required. This demand for national treatment has not come from foreign investors; it has come from Chinese invested enterprises. In , the Deng Xiaoping government sought to attract foreign investment to China by offering significant incentives to foreign investors, including the following:. These incentives encouraged a flood of foreign investment into China. This same sort of distortion applied to various other business incentives and in the early s, private Chinese companies started complaining about it being difficult to compete with foreign owned enterprises.
Beginning in , the Chinese government started removing and reducing various foreign company benefits. Foreign owned enterprises were made subject to corporate income tax at the same rate as Chinese owned companies. The full personal income tax and social benefit system was imposed equally on both Chinese employees and foreign employees. Local governments were prohibited from offering land and tax breaks to lure foreign investment. By , there were virtually no incentives left for foreign invested enterprises.
The new FIL should be seen as the final nail in the foreign incentive coffin. Foreign invested companies will now receive no incentives or benefits at all. They will be treated the same as any private Chinese company. Most importantly, they will be entirely under the control of the CCP and the Chinese government. Among other things, this will mean the following:. When the CCP arrives to set up a party branch in a foreign enterprise, compliance by the foreign enterprise will be required.
When the CCP branch insists on reviewing confidential foreign company business records, compliance by the foreign company will be required. When the foreign company is told it can no longer use its international VPN to get access to necessary news and information, compliance by the foreign company will be required. When the foreign company is told that all company data must be stored on a cloud server located in China and accessible to the Chinese government, compliance will be required by the foreign company.
This argument was never a strong one, but it largely worked. And yet, the new FIL does not really put foreign invested enterprises on an even footing with Chinese invested companies; that too is an illusion. Foreign investors will only be permitted to invest in business sectors not on the negative list and the new negative list will be virtually identical to the current list.