The Resource Seconded UK employees as a permanent establishment in China
Seconded UK employees as a permanent establishment in China
Resource Information
The item Seconded UK employees as a permanent establishment in China represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.This item is available to borrow from 1 library branch.
Resource Information
The item Seconded UK employees as a permanent establishment in China represents a specific, individual, material embodiment of a distinct intellectual or artistic creation found in International Bureau of Fiscal Documentation.
This item is available to borrow from 1 library branch.
- Summary
- Under the China-UK double tax agreement, UK firms deriving profits in China are protected from Chinese tax liabilty on the profits unless the profits are derived through a permanent establishment (PE). Unlike the original 1984 treaty between China and the UK, the current treaty, effective from 1 January 2014, deems a UK company to have a PE in China in some circumstances where its employees provide services in China, including services provided to its subsidiaries, for more than 183 days in a 12 month period. Where this happens, the profits of the deemed PE will be subject to Chinese company income tax. The profits will normally be calculated as a percentage of the service fee paid to the UK employer for the services provided by its employees. This article explores the circumstances in which a UK employer can find itself with a deemed PE in China when seconding its employees to work in its Chinese subsidiaries and, when this happens, how its tax liability may be calculated
- Language
- eng
- Label
- Seconded UK employees as a permanent establishment in China
- Title
- Seconded UK employees as a permanent establishment in China
- Language
- eng
- Summary
- Under the China-UK double tax agreement, UK firms deriving profits in China are protected from Chinese tax liabilty on the profits unless the profits are derived through a permanent establishment (PE). Unlike the original 1984 treaty between China and the UK, the current treaty, effective from 1 January 2014, deems a UK company to have a PE in China in some circumstances where its employees provide services in China, including services provided to its subsidiaries, for more than 183 days in a 12 month period. Where this happens, the profits of the deemed PE will be subject to Chinese company income tax. The profits will normally be calculated as a percentage of the service fee paid to the UK employer for the services provided by its employees. This article explores the circumstances in which a UK employer can find itself with a deemed PE in China when seconding its employees to work in its Chinese subsidiaries and, when this happens, how its tax liability may be calculated
- Citation source
- In: British tax review. - London. - (2016),
- http://library.link/vocab/creatorName
-
- Guo, W
- Krever, R.E
- Teoh, J. (Jonathan)
- Language note
- English
- http://library.link/vocab/subjectName
-
- PE
- secondment
- service fee
- services PE
- tax treaty
- tax liability
- Label
- Seconded UK employees as a permanent establishment in China
- Label
- Seconded UK employees as a permanent establishment in China
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Seconded-UK-employees-as-a-permanent/6aslIoo77GA/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Seconded-UK-employees-as-a-permanent/6aslIoo77GA/">Seconded UK employees as a permanent establishment in China</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="https://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
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<div class="citation" vocab="http://schema.org/"><i class="fa fa-external-link-square fa-fw"></i> Data from <span resource="http://link.library.ibfd.org/portal/Seconded-UK-employees-as-a-permanent/6aslIoo77GA/" typeof="Book http://bibfra.me/vocab/lite/Item"><span property="name http://bibfra.me/vocab/lite/label"><a href="http://link.library.ibfd.org/portal/Seconded-UK-employees-as-a-permanent/6aslIoo77GA/">Seconded UK employees as a permanent establishment in China</a></span> - <span property="potentialAction" typeOf="OrganizeAction"><span property="agent" typeof="LibrarySystem http://library.link/vocab/LibrarySystem" resource="http://link.library.ibfd.org/"><span property="name http://bibfra.me/vocab/lite/label"><a property="url" href="https://link.library.ibfd.org/">International Bureau of Fiscal Documentation</a></span></span></span></span></div>
