The State Administration of Taxation (SAT) issued a ruling on implementation of treaty articles on 26 January 2010 (Gui Shui Han [2010] No. 46). The ruling supplements a previous ruling regarding the article on royalties (Guo Shui Han [2009] No. 507). The content of the new ruling is summarized below.
As a general rule, technical services related to the transfer of the right to use proprietary technology constitutes part of the technology transfer; hence, the in…