SAT clarifies when assignment/secondment arrangements create Permanent Establish
First 15 minutes is for networking Light refreshments included
Hosted by the Taxation Committee and the China Business Committee It is not uncommon for the U.S. or Hong Kong based companies to second employees to their related companies in China. From a tax perspective, whether and to what extent such seconded employees would constitute a permanent establishment ('PE'), which would give rise to potential China tax implications on overseas companies including the U.S. or Hong Kong based entities in PRC. The PRC's State Administration of Taxation ('SAT") issued guidance (Bulletin 19) on 19 April 2013 provides welcome clarification of the PE risk associated with certain secondment arrangements and also directs the Chinese tax authorities to undertake a robust review of documentation and the substance of secondment arrangements, and sets out the type of documentation/information that companies should maintain to minimize challenges.
During the seminar, we will discuss following key areas: 1) Potential tax implications arising from expatriate assignment and secondment arrangements 2) Guideline of tax filing, other compliance requirements and considerations in making such arrangements from PRC income tax perspective 3) Tax planning ideas in accordance with the Bulletin newly released by the SAT
The American Chamber of Commerce in HK 1904 Bank of America Tower 12 Harcourt Road Central, Hong Kong