A management-fee invoice without people, deliverables and TP support is how deductions and remittances both die.
Related-party service fees (HQ management, IT, secondment recharge) sit at the junction of CIT deductibility, VAT/fapiao, WHT, transfer pricing and outbound FX. Substance — who did what in China — beats a template agreement. This tax wiki focuses on deductibility/TP/WHT framing. The live FX route page owns bank/SAFE remittance choreography — link it,. Thin capitalisation matters when the ‘fee’ is really interest.
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 services were actually performed?
Substance.
WorkTP method support?
Docs related pages.
TPWHT/VAT on the fee?
Character.
TaxBank pack ready?
FX twin.
FXWorking 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.
Can we remit without a contract?
Banks and tax alike hate it. Put the paper trail first.
Where is the FX how-to?
Primary authorities
Reviewed sources support orientation, not a fact-specific assessment.