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Direct Tax
The ruling excludes vacation and business development days from service PE calculations and confirms virtual services from abroad don’t count, potentially reshaping compliance for multinationals
February 3, 2026
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  • The Year of the Sheep, now drawing to a close, has been a signature year both economically and fiscally for China. China had surpassed the US as the world's largest economy, in purchasing power parity terms, in 2014. It had similarly become the world's largest recipient of foreign direct investment (FDI), also overtaking the US, in that year. Remarkably, while China takes the top position as a recipient of FDI, Chinese outbound direct investment (ODI) is projected to overtake FDI for 2015 as a whole, making China a net exporter of capital. Projections further show China overtaking the US in ODI terms to become the world's premier source of ODI within a short few years. There is no doubt that China is becoming ever more central to the global economic order. Nevertheless, as the Chinese government seeks to shift her economy from reliance on investments, exports and heavy industries to a more consumption and service sector-driven model, the pace of economic expansion in China will ease off before picking up again. In the meantime, the government will go to every length to safeguard her tax revenues.
  • The progress with, and challenges of, rolling out the FATCA and CRS technology and platforms in Hong Kong and Chinese financial institutions is the focus of this chapter by Charles Kinsley, Khoonming Ho and Lewis Lu
  • The G20/OECD BEPS proposals are being rolled out into Chinese tax law and practice, with implications for multinational enterprises (MNEs) doing business in China. The focus of this chapter by Chris Xing, William Zhang, Lilly Li and Conrad Turley is recent and upcoming regulations and guidance which are positioning China at the forefront of global BEPS implementation

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