Reply of the Offshore Oil Taxation Bureau of the Ministry of Finance on the Determination of Employers for Personnel Sent to China by Engineering Contracting or Leasing Companies of Contracting States

This document clarifies that the tax treatment of personnel sent to China by foreign companies for offshore oil exploration, development, engineering contracting, or equipment leasing services is distinct from general equipment installation services, and that their wages and salaries are deemed paid by the foreign employer. The document has been fully annulled as of March 24, 2025, pursuant to State Taxation Administration Order No. 59.