On 14 September 2009, the State Administration of Taxation (SAT) issued Guoshuihan (2009) No. 07 (the Circular) to clarify the tax treaty treatment of royalties (including under the China-Hong Kong and China-Macau tax arrangements). The Circular, which takes effect on 1 October 2009, summarizes the tax treaty treatment of royalties as follows:
| - | "Payment received for the use of industrial, commercial or scientific e… |