I. The term “permanent establishment” in tax treaties encompasses that “the furnishing of services, including consultancy services, by an enterprise of a Contracting State through employees or other personnel in the other Contracting State, provided that such activities continue for the same project or a connected project for a period or periods aggregating more than six months within any twelve-month period. ” In actual practice, if a foreign enterprise, which has no permanent establishment within China, only sends its employees to provide services, including consultancy services, for a connected project within China, when these employees' actual working period or periods aggregating more than six months within any twelve-month period, it may be determined that this foreign enterprise has a permanent establishment within China.

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