ForTran advises non-resident individuals and enterprises on their tax obligations and status in China. With extensive experience in cross-border matters involving inbound investments, we help clients understand and manage the implications of Chinese tax residency rules, permanent establishment (PE) thresholds, and income sourcing principles.

Tax Residency and PE Determinations

We assist clients in assessing whether an entity incorporated under foreign law but with its place of effective management in China constitutes a Chinese tax resident enterprise. For non-resident enterprises, we provide detailed guidance on whether their operations in China—such as representative offices, service facilities, or dependent agents—give rise to a permanent establishment and what the resulting tax exposures may be.

Income Sourcing and Tax Exposure

We help clients determine whether income is deemed China-sourced under PRC tax law, including income that may arise offshore but is effectively connected to Chinese operations. Our services also cover treaty analysis, withholding obligations, and the allocation of profits between domestic and offshore entities.

Tax Considerations for Dual or Renounced Nationality

For individuals renouncing Chinese citizenship or holding multiple nationalities, we advise on the resulting challenges in identity determination, asset disposition, and compliance obligations. Our nationwide team and international cooperation network enable us to navigate both PRC rules and foreign disclosure or tax regimes.