The certainties and uncertainties brought about by China’s latest tax circular on foreign international transportation companies
The State Administration of Taxation (SAT) recently released an SAT Public Notice  No.37 (Public Notice No.37) to set forth the latest tax administration rules (mainly from the corporate income tax perspective) on non-tax resident enterprise (non-TRE) international transportation companies. It abolished several existing tax circulars regarding Non-TRE international transportation companies.
Some changes in tax treatment and administrative procedures are critical to the Non-TRE industry players. A few issues that remain to be clarified by the Chinese tax authorities are too important to be ignored. The non-TRE international transportation companies, their agents and the end customers in China (which may also be affected) are suggested to assess the tax implications and the potential extra administrative cost to be incurred in light of this latest development.
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