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In recent years more and more foreign accounting offices, auditing companies, law firms and consulting companies (hereinafter referred to as consultation enterprises) have come to China to conduct taxation, accounting, auditing, law and consulting businesses (hereinafter referred to as consultation business or services). Some overseas consultation enterprises have set up in China enterprises with foreign investment that are engaged in consultation business, and some have set up representative offices in China. In some cases, overseas consultation enterprises participate in consultation business in China by sending personnel directly to China to do the business, or cooperating with consultation enterprises with foreign investment or representative offices in China. To standardize taxation management, the State Bureau of Taxation issued on May 12, 2000 the Circular concerning Taxes for Enterprises with Foreign Investment and Foreign Enterprises Engaged in Consultation Business (Guo Shui Fa [2000] No.82), which regulates the taxation on incomes obtained by foreign-invested enterprises, representative offices and overseas consulting businesses from consulting activities in China.

　　In cases where the overseas enterprise sends personnel to China to participate in the said consultation business, its income share shall again be segmented according to places of occurrence into a domestic part, which should be no less than 50 percent of its total share and should be reported for business and income taxes in China.