Many enterprises in Hong Kong that conduct business in China are unaware that these activities may constitute a permanent establishment (PE), which thus subjects them to corporate income tax in China.
In recent years, China's tax authorities have tightened the tax administration and scrutiny over PEs; as such, it is a very important area of which companies need to be mindful. PEs can be created in many different ways and can take many different forms: there are fixed place PEs, construction PEs, agency PEs and service PEs.
Paul Dwyer, Dezan Shira & Associates' Director and Head of International Tax and Transfer Pricing - Asia Pacific, will provide an overview of the PE concept, how a PE can be created under the PRC-Hong Kong tax treaty, and summarize some of the strategies that are commonly used to potentially mitigate PE risk.
The presentation will include an overview of Circular 75 (which sets out China's current interpretation regarding the implementation of Double Taxation Agreements) as well as Public Notice 11 (issued by the China tax authority to update its interpretation of a few articles under DTAs concluded by China as well as other DTA treatments).
First 15-20 minutes is for networking
Sandwiches and beverages included
Hosted by the Taxation Committee