SolvedDT4904 | Double Taxation Relief Manual: China: Notes
From HM Revenue & Customs · Double Taxation Relief Manual
Taxation of services
Article 5 (Permanent establishment) deems a permanent establishment to exist where services have been furnished in China by a UK enterprise, through employees or other personnel, for a period or periods aggregating more than 183 days in any twelve-month period commencing or ending in the fiscal year concerned.
Anti-abuse
The dividend, interest, royalties and other income articles contain anti-treaty shopping rules.