According to Art. 28 of the Enterprise Income Tax Law, qualifying low-profit enterprises are taxed at a reduced income tax rate of 20%.
On 3 July 2008, the State Administration of Taxation issued a Notice (GuoShuiHan [2008] No. 650) announcing that non-residents do not qualify for the above-mentioned tax incentive. The Notice clarifies that "low-profit enterprises" are enterprises whose income from all production and taxable activities are taxable in China, and…