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China Tax & Investment News | Fifth Protocol to Mainland-HK DTA signed – Article on Teachers and Researchers is newly introduced and threshold on Dependent agent PE is lowered
China Tax & Investment News (CTIN) is a bilingual thought leadership prepared by EY’s China Tax Center team and distributed in PDF to all EY clients which have subscribed to EY email notifications. Different from China Tax & Investment Express (CTIE), which is a weekly quick briefing on multiple rules/regulations/polices officially issued in that period, CTIN – normally focusing on one ruling or one type of issues/industries each issue - provides more detailed interpretation and in-depth business implication analysis on significant policies as well as trends of development in tax and business related areas.
Recently, the Mainland of China and the Hong Kong SAR signed the Fifth Protocol to the Mainland-HK Double Taxation Arrangement (DTA). The Protocol brings about new benefits for teachers and researchers but it facilitates the triggering of a dependent agent permanent establishment (PE). According to the Mainland-HK DTA, the Fifth Protocol shall, upon written notification by both sides of the completion of their respective required approval procedures, enter into force on the date of the later of these notifications.
This issue of China Tax & Investment News aims to discuss the main changes that the Protocol brings about and share our views thereon.
For more information, please contact your usual EY contact or one of the EY’s China tax leaders in the list attached at the end of this tax alert.