Reply of the Offshore Oil Taxation Bureau of the Ministry of Finance on the Interpretation of the Term 'Offshore' in the China-Norway Tax Treaty

This document clarifies that the term 'offshore' in the China-Norway tax treaty refers to China's internal waters, territorial sea, continental shelf, and other sea areas under China's jurisdiction over marine resources, and specifies that the 39/11 and 29/04 blocks in the South China Sea fall within this scope, thereby determining the tax treatment of technical services provided by a Norwegian company.