Current-law scope and cautions
- For an individual without domicile in China, 183 days is a key IIT residence test; domicile can independently create PRC tax residence. The day count is not a standalone corporate PE test.
- China-source employment income and treaty dependent-services rules can apply even where the worker is not a PRC tax resident.
- PE depends on the applicable tax treaty, enterprise activities, fixed-place/dependent-agent facts and treaty exceptions.
Use: This is a screening/estimation tool, not legal, tax, accounting or regulatory advice. Confirm the latest primary authority, regulator/exchange practice, local rules and transaction documents before acting.
