If China-source passive or certain service income is paid outbound, assume WHT analysis — ‘net of tax’ contract wording is not a clearance.
PRC withholding tax commonly applies to dividends, interest, royalties and specified China-source payments to non-residents. Domestic rates can be reduced under tax treaties if relief procedures and beneficial-owner tests are met. Banks and SAFE flows often expect tax docs before remittance. This wiki is the WHT definition. Treaty relief and BO test are related pages. Dividend repatriation and related-party fees connect the payment story. Domestic CIT on a PE is a different track.
4 questions before you choose the route.
This page identifies the right question and evidence. It does not determine the legal outcome on a reader’s facts.
What income type?
Dividend/interest/royalty/service.
TypeDomestic rate vs treaty path?
Relief related pages.
RateWho is beneficial owner?
BO related pages.
BORemitting through which bank?
FX docs.
BankWorking rule: Map the regulated role before marketing or launch in China.
The signal ledger.
These facts move the question beyond a label and into a product, money-flow and control analysis.
Bring a compact evidence docket—not a pitch deck.
Give a compliance team or counsel the operating facts that reveal the perimeter.
Questions people ask before they build.
Short answers for orientation. The right result can change with the service model and current rules.
Is service fee always WHT?
Depends on China-source analysis and PE risk. Not automatic for every offshore invoice.
Where is treaty relief?
Open /china-tax-treaty-relief.
Primary authorities
Reviewed sources support orientation, not a fact-specific assessment.