DT4904 - Double Taxation Relief Manual: Guidance by country: China: Notes

Taxation of services

Article 5 (Permanent establishment) deems a permanent establishment to exist where services have been furnished in China by a UK enterprise, through employees or other personnel, for a period or periods aggregating more than 183 days in any twelve-month period commencing or ending in the fiscal year concerned.

Anti-abuse

The dividend, interest, royalties and other income articles contain anti-treaty shopping rules.