Salient points are set out as follows:
- Clarification of permanent establishment (“PE”) for Sino-foreign co-operative education institutions and the 6-month period threshold for service PEs;
- Amending the scope of international shipping and air transportation income under DTAs;
- Comprehensive interpretations of the DTA article involving Artists and Sportsmen; and
- New interpretations for DTA treatment of partnerships, both domestic and foreign, and their partners.