According to our observations, Chinese entrepreneurs have become more aware of tax issues when considering offshore investments. One of their first questions in this regard is often whether income received from their Swiss affiliates would be taxed both in Switzerland and in China, or whether comparable taxes would be imposed for the same item by both the Swiss and Chinese tax authorities.
Double taxation is harmful to the international exchange of goods and services, and cross-border movements of capital, technology and persons. In recognition of the need to remove this obstacle, the Swiss government has concluded double taxation agreements (DTAs) with more than 90 countries; the Sino-Swiss DTA has been in effect since 1991.
According to the Sino-Swiss DTA, the profits of an enterprise of a contracting state will be taxed only in that contracting state, unless the enterprise carries on business in the other contracting state through a permanent establishment (PE) situated there.
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Christoph Niederer is partner and head of the tax team at the Swiss law firm Vischer, and Wu Fan is counsel at Vischer
电话 Tel: +41 58 211 34 00
传真 Fax: +41 58 211 34 10
电话Tel: +41 58 211 34 37
吴帆 Wu Fan
电话Tel: +41 58 211 36 45