Taxation of sponsorship agreements in China - the rules for International Sports Federations without permanent establishment
Published 29 January 2019 By: Guo Cai
It is not uncommon nowadays to spot Chinese companies' profiles at international sports events such as the 2018 FIFA World Cup and Pyeongchang Winter Olympics. Alibaba Cloud tied the knot with the International Olympic Committee confirming its Olympics Partner (TOP) status, and Alipay marched into the UEFA national men's competitions not only aiming for Chinese fans travelling to Europe for UEFA Games, but also carrying the ambition to "build awareness of Alipay's brand worldwide before a potential expansion beyond its home market".1 Chinese companies are riding the trend to sponsor international sports events in exchange for greater international impact. Such sponsorship deals will usually generate income derived from Mainland China (hereinafter referred to as “China”).
The author of this article has been receiving enquiries from international sports organizations and federations (IFs) regarding relevant tax obligations for IFs without permanent establishments in China. This article is intended to clarify these questions. For the purpose of this article, “permanent establishments” refers to a fixed place of business through which the business of an enterprise is wholly or partly carried on.2
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- Tags: Agreements | China | Commercial | Contract | Enterprise Income Tax | Football | Olympics | Sponsorship | Tax | UEFA | Urban Construction Tax and Educational Supercharges | Urban Construction Tax and Educational Surcharges | Value-added Tax (VAT)
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Attorney, Jin Mao Law Firm
Ms. Guo Cai oversees the LexVeritas Sports and International Law Group, Jin Mao Law Firm (People's Republic of China), the first Chinese law firm to have a practice group dedicated to the sports industry. Ms. Cai graduated from Harvard Law School and China University of Political Science and Law. She also held an LLM in Human Rights (distinction) from the University of Hong Kong. Admitted to practice in China and the US (New York), Ms. Cai specialises in international dispute resolution and sports law, growing with the Chinese sports industry and connecting international best practice with sports in China.