The Ministry of Finance and State Administration of Taxation jointly issued a notice (Cai Shui [2008] No. 130) on 28 September 2008 to state that the passive income derived by a non-resident enterprise referred in Para. 3 of Art. 3 of the Enterprise Income Tax Law (EITL) must be taxed on a gross basis. In determining taxable income, no taxes or fees can be deducted unless otherwise provided …