What is the Feasibility & Structure of Entry?

Entering China is a sequence, not a decision. Feasibility, regulatory mapping, entity, WFOE: structure follows the operating model, never the reverse. In the right order entry is cheap. Backwards, it compounds.

Entry ~ Volume 1

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Licensed Business Items SAMR Standardized Scope VAT Invoice Fapiao

Business Scope Wording That Quietly Blocks Your Invoices

Standardized market regulation scope wording maps directly to tax classification codes, where missing service terms trigger automated tax bureau invoicing halts.

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State Taxation Administration Hong Kong Companies Registry Registered Capital Subscription

Hong Kong Holding Layer against Direct Foreign Ownership

A Hong Kong holding layer insulates parent equity, lowers Mainland dividend withholding tax to five percent, and accelerates offshore corporate restructuring.

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Legal Representative Liability RMB Basic Account Golden Tax System Phase IV

The Filing Queue from Name Approval to Bank Account

Corporate incorporation in China requires exact filing alignment from scope selection and apostille authentication through chop carving to tax activation.

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Enterprise Income Tax Customs Clearance Foreign Exchange Registration

Selling into China without an Entity and Where That Stops

Cross-border selling without a China entity works via DDP or agents but stops when local fapiao, restricted licences, or onshore service teams create tax PE.

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Attestation Procedures National Industry Classification Power of Attorney Notarization

Verification Procedures for Hong Kong Attested Corporate Dossiers in Mainland Registration

Verify Hong Kong attestation seals and align corporate names across statutory returns to pass mainland registration counters without file rejections.

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Mainland Operating Subsidiary Non Resident Withholding Tax Common Reporting Standard

Mainland Tax Bureau Enforcement Limits on Offshore HoldCo Operational Substance under Treaty Provisions

Mainland tax bureaus limit treaty benefits to offshore holding entities proving active local management, physical operations, and direct economic risk.

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Customs Duty Valuation Embedded Software Transactional Net Margin Method Dianzi Shuiwuju Tax Portal Registration

Cross Border Software Royalty Remittance Tax Classification Friction under China Transfer Pricing Audit Rules

Cross-border software remittances require technology import registration, distinct contractual fee segregation, and DEMPE functional alignment under Bulletin 42.

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Article 37 EIT Law STA Circular 2010 No 19 City Construction Tax

Tax Withholding Permanent Establishment Exposures and Filing Sequences for Non Resident Sales

Non-resident sales into China face immediate withholding tax levies and Permanent Establishment exposure, requiring strict contract pricing split schedules, current-year tax residency certificates, and sequential Bulletin 37 and Bulletin 40 filings before bank cross-border wire execution can proceed.

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Transfer Pricing Transfer Pricing Benchmark PRC Company Law Article 210

Dividend Repatriation against Service Fee Routes out of China

Service fee routes trade higher up-front tax friction and audit risk for rapid liquidity, while dividends require statutory reserves and profit audit.

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Tripartite Severance Agreement Foreign Invested Enterprise Labor Dispatch

Employer of Record Arrangements against a WFOE Payroll

EOR structures in China face strict 10% labor dispatch caps and high PE tax risks, making WFOE direct payroll financially superior within 12 months.

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Transfer Pricing Intangible Asset Import Service Permanent Establishment

Standardized Tax Classification Codes Governing Cross Border Software Licensing

Cross-border software licenses require exact 19-digit tax classification code matching to clear bank remittance and tax withholding queues in China.

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SAMR Scope Drafting Registered Capital Municipal AMR Portals

State Administration for Market Regulation Scope Drafting and Licensing Integration

Drafting standardized SAMR business scopes requires explicit alignment between sectoral licensing triggers, tax invoice categories, and 5-year capital schedules.

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Foreign Exchange Capital Account Tax Clearance Certificate Fapiao Invoicing

The Ways a Foreign Company Can Legally Operate in China

Operating legally in China requires selecting the correct entity form, matching registered business scope to invoice lines, and sequencing bureau filings.

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Bulletin 6 Bulletin 16 Secondary Adjustments

State Taxation Administration Transfer Pricing Adjustments on Offshore Parent Service Remittance Contracts

Offshore service remittances fail tax clearance when intercompany agreements lack granular deliverable proof, triggering disallowance and dividend tax reclassification.

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Allocation Keys Permanent Establishment 183 Day Rule Central Parity Rate

Structuring Contemporaneous Documentation for Offshore Parent Service Remittance Tax Clearances

Structure contemporaneous evidence logs showing direct operational benefits to satisfy tax bureau reviews and clear offshore parent service remittances.

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Transactional Net Margin Method Critical Assumptions Article 25 DTA

Resolving Transfer Pricing Adjustment Double Taxation through Bilateral Advance Pricing Agreements under Tax Treaties

Bilateral Advance Pricing Agreements resolve double taxation by legally binding both tax authorities to unified transfer pricing methodologies and rollback rules.

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Comparable Uncontrolled Price Corporate Income Tax Law Article 41 Foreign Exchange Remittance

Intercompany Service Agreement Drafting Fundamentals under PRC Bulletin 16 Rules

PRC Bulletin 16 mandates explicit contractual deliverables, direct economic benefit proof, and arm's length markup benchmarking for deductible service fees.

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Profit Attribution Service Permanent Establishment Advance Pricing Agreements

Resolving Intercompany Service Permanent Establishment Exposure Risks under Chinese Bilateral Tax Treaties

Mitigate Chinese service permanent establishment exposure by structuring clear economic employer boundaries and aligning intercompany fees with local tax benchmarks.

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Master File Requirements State Taxation Administration Law on the Administration of Tax Collection Article 54

Drafting Compliance Standards for Outbound PRC Intercompany Contracts

Drafting outbound PRC intercompany contracts requires precise service scopes, benefit evidence, transfer pricing mark-ups, and tax clearance compliance.

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Advance Pricing Agreements Public Notice 2016 No 64 Public Notice 2017 No 40

Resolving Cross-Border Double Taxation Risks through Bilateral Mutual Agreement Procedures under PRC Treaties

PRC Mutual Agreement Procedures require dual central and provincial filings to suspend tax collections and eliminate double taxation exposure.

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Bilateral Social Security Agreement Individual Income Tax Law Non Markup Cost Certification

Evaluating Economic Employer Doctrine Principles under Chinese Secondment Rules

China reclassifies foreign secondment wage recharges as taxable service fees whenever the local entity operates as the true economic employer under Bulletin 19.

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Dual Language Contract Drafting Tax Record Filing for Outbound Payments Value Added Tax Surcharges

Structural Compliance Standards for Outbound PRC Intercompany Contracts

Outbound PRC intercompany contracts demand documented economic benefit, cost-plus pricing caps, and upfront tax clearance for remittances exceeding fifty thousand dollars.

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Transfer Pricing Audit Intercompany Account Settlement SAFE Circular 16

Navigating Corresponding Adjustments and Secondary Adjustments in Chinese Tax Audits

Chinese tax audits trigger primary profit additions and secondary dividend withholding, requiring immediate MAP treaty filings and SAFE registration to prevent double taxation.

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Transactional Net Margin Method Residual Profit Split Enterprise Income Tax Law Article 48 Late Interest

Transfer Pricing Assessment Methodologies for Outbound Related Party Technology License Royalty Allocations

Outbound technology royalty allocations in China require proving local economic benefit under DEMPE principles to preserve corporate income tax deductions.

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Domestic Trade Agent General Administration of Customs Dutiable Transaction Value

Cross Border Trade Regulations and Tariff Mechanics without Local Entities

Cross-border trade into China without a local entity requires structured agent import or bonded warehouse models to meet mandatory customs and tax rules.

Labor Dispatch Foreign Exchange Registration Business Scope Drafting

Employer of Record Compliance against Direct Corporate Payroll

Direct WFOE payroll provides complete legal IP sovereignty and lower landed cost over EOR dispatch for China teams exceeding four employees.

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Tax Data Matching Individual Income Tax Withholding Daily Late Payment Surcharge

Cross Regional Social Insurance Contribution Arbitrage Penalties under Golden Tax Phase Four

Golden Tax Phase IV cross-matches income tax withholding with social insurance accounts, triggering automated tax assessments and fines for regional payroll arbitrage.

Technology Import Contract Local Surcharges Red-Ink Invoice Cancellation

Tax Classification Code Assignment for Software Royalty Remittances

Assigning tax classification code 3040407000000000000 to software royalties mandates 10 percent CIT withholding and 6 percent VAT via Golden Tax Phase IV.

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Business Scope Foreign Investment Negative List Shanghai Service Online

Standardized Enterprise Activity Selection under State Market Supervision Rules

Standardized enterprise activity selection under State Market Supervision rules requires mapping planned operations directly to catalog codes to secure tax invoice activation.

Benefit Test SAFE Foreign Exchange Remittance Transfer Pricing

Transfer Pricing Allocation Keys and Benchmark Markups under PRC Bulletin 6

PRC Bulletin 6 enforces strict six-test scrutiny on intra-group service fees, requiring operational allocation keys and local Chinese markup benchmarks to secure CIT deductions.

Entry

Feasibility & Structure

What the firm knows, published