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magazine
Transazioni internazionali con parti correlate
- November 2012
- Members Access
Affronteremo in questo numero, come suggerisce il titolo, alcuni aspetti fondamentali delle transazioni internazionali con le parti correlate.
magazine
Establishing a Business in India
- November 2012
- Members Access
Expats working in India and business people visiting the country for the first time generally agree that India is different; that it stands apart from other developing nations in the business opportunities it presents.
magazine
International Related Party Transactions
- November 2012
- Members Access
In this issue of China Briefing, we turn once again to the issue of international transactions, specifically those between related parties. In the first article, we focus purely on HQ-WFOE service agreements; in the second article, we give a very bri...
Q&A
How is residency defined under Indian law?
- November 2012
- Members Access
Personal taxation in India depends on the income source and a person’s residential status, which is determined by the length of time spent in India. Residential statuses include: resident and ordinarily resident (ROR), resident but not ordinari...
Q&A
What should Chinese foreign-owned subsidiaries bear in mind when entering into s...
- November 2012
- Free Access
The subsidiaries must provide the services that are within their business scope. For foreign-invested commercial enterprises or manufacturing wholly-owned foreign enterprises, the services must be provided in relation to their business scope...
Q&A
What are the common service agreements between Chinese foreign-owned subsidiarie...
- November 2012
- Free Access
Indeed, service agreements vary largely based on the service that will be provided, however the main types of service agreements might include: Consulting services Commission agency services After-sales or technical support services
Q&A
What are the main terms that should be included in service agreements between re...
- November 2012
- Free Access
The following items are advised to be included: The scope of services The fees for such services The payment method of such fees The liabilities when problems arise Other miscellaneous terms that the parties think fit
Q&A
When do tax liabilities arise in terms of services provision under Chinese law?
- November 2012
- Free Access
As long as the service recipient or the service provider is located in China, tax liabilities will arise on the service income, notwithstanding the location of the provision of services. Indeed, the Chinese subsidiaries are the ones responsible for w...
Q&A
Is there any difference if the foreign headquarter is deemed to have a permanent...
- November 2012
- Free Access
If a permanent establishment status is found for the foreign headquarter, a 25 percent corporate income tax will be payable on the service income. The tax rate is a deemed profit rate, which is determined by the tax authorities. Furthermore, the fore...
Q&A
What factors are to be taken into consideration whether a foreign-invested entit...
- November 2012
- Free Access
What factors are to be considered when a foreign-invested entity is planning to constitute a permanent service establishment in China?
Q&A
What are the requirements for transfer pricing in China?
- November 2012
- Free Access
The current system is largely based on the guidelines of OECD. The newest update on transfer pricing is the one promulgated in 2009 by the State Administration of Tax. The Chinese transfer pricing system is based on the arm’s length principle....
Q&A
What is the definition of related parties under Chinese law?
- November 2012
- Free Access
There are many ways to be categorized as related parties, which includes: Ownership or control; Debts Senior/ executive management appointment Licensing of intangibles Raw materials/ spare parts control or supply Service provision or receipt ...
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