In October 2017, the State Administration of Taxation (SAT) released the Public Notice on the Matters Regarding Withholding Corporate Income Tax (CIT) at Source for Non-Tax Resident Enterprises (Non-TREs) (SAT Public Notice  No. 37, PN 37). PN 37 shall take effect from 1 December 2017 and replace a series of important circulars, such as Circular Guoshuifa  No.3 (Circular 3), etc.
PN 37 streamlines the withholding regime in a comprehensive way. In comparing PN 37 with the existing circulars, notable changes are:
PN37 will bring significant changes to the way that non-TREs fulfil their China tax obligation, and withholding agents perform their withholding obligation, in all aspects of cross-border transactions. Parties to any cross-border transaction should pay particular attention to these new rules.
Lead Partner, China Outbound Investment Service; China North Tax Leader, PwC Hong Kong
Tel: + (10) 6533 2100