permanent establishment

Double Tax Treaty Between China and Switzerland

Switzerland and China signed a new tax treaty on September 25, 2013 in order to avoid double taxation and to prevent from fiscal evasion as regards taxes on income. The new Treaty replaces the existing treaty from 1990. The agreement has become effective since November 15, 2014 and applies to income derived on or after January 1, 2015.

The key features of the main changes are summarized in this table:

CHINA-SWITZERLAND: THE NEW DOUBLE TAXATION AGREEMENT

Recently China and Switzerland re-negotiated the double taxation agreement that has been in existence since 1990 and signed a new double taxation agreement “DTA”. The new agreement still has to go through referendum in Switzerland so its enforceability is still uncertain. However, if everything goes as planned, it’s expected to become effective some time next year.

GUIDANCE ON WHEN STAFF SECONDMENT CREATES TAXABLE PRESENCE IN CHINA

Along with the speedy development of China’s economy and globalization, the need for skilled resources in China is escalating. This has led to an increase in the mobility of human resources to China. Increasingly, multinational companies (“MNCs”) with set up in China are looking for talents within their existing work force from their operations around the world and dispatch them on temporary arrangements to China to assume key technical, management or other positions with the Chinese entity.

Beijing - Shanghai - Shenzhen - Hong Kong - Paris
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