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.
Who is on the ground and for whom?
People map.
PeopleWho signs or habitually brokers?
Agent PE.
AgentTreaty PE article applicable?
Definition shifts.
TreatyInvoices offshore only?
Not a shield.
InvoiceWorking rule: Permanent establishment concepts under domestic law and treaties can create a China taxable presence for foreign enterprises: fixed places, construction sites, service PEs, and dependent-agent PEs.
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.
Does a representative office always create PE?
RO is a regulated presence with its own rules; PE analysis for other models is separate. Get counsel.
Where are CIT rates?
Use the linked specialist resource when Permanent Establishment in China turns on detailed evidence, procedure or risk assessment.
Primary authorities
Reviewed sources support orientation, not a fact-specific assessment.