Treaty detail
China - Philippines tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
1999-11-18
Effective
2001-01-01
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 15% · Corporate rate: 10%
The China-Philippines treaty distinguishes between qualifying corporate shareholders and other beneficial owners. The corporate-rate threshold and any preferential treatment should be confirmed against Article 10.
Interest
Rate: 10%
Government-related interest and interest paid to certain financial institutions may benefit from reduced rates or full exemption under Article 11.
Royalties
Rate: 15%
Royalty treatment under this treaty caps the source-country rate at a higher level than in many modern treaties. Practitioners should confirm the rate against Article 12 for the specific royalty category.
Permanent establishment
Construction threshold: more than 6 months
Dependent-agent rules apply where a person habitually concludes contracts or maintains a stock of goods on behalf of the enterprise.
Other treaty flags
Pension taxation is generally allocated to the residence state, with separate rules for government-service pensions.
Seeded article summaries
Article 4
Residence
Defines treaty residence and is the gateway to any benefit under the treaty.
Residence under the China-Philippines treaty matters for cross-border BPO arrangements, Chinese-invested infrastructure projects in the Philippines, and expatriate workers.
Article 5
Permanent Establishment
Sets the business-presence threshold with a services-PE element.
The China-Philippines treaty includes both a construction threshold and a separate services threshold, which is common in treaties between Asia-Pacific economies.
Article 7
Business Profits
Reserves business profits to the residence state absent a permanent establishment in the other state.
Article 7 is the operating rule for Chinese contractors and consultants serving Philippine customers without a fixed base, and the reverse.
Article 10
Dividends
Provides the treaty cap on cross-border dividend withholding.
Article 10 distinguishes between qualifying corporate shareholders and other beneficial owners. The precise thresholds should be confirmed against the official text.
Article 11
Interest
Caps source-country withholding on cross-border interest with government-interest carve-outs.
Article 11 caps the general rate at 10 percent. Government-related and qualifying financial-institution interest may benefit from broader treaty exemptions.
Article 12
Royalties
Caps source-country withholding on royalties at a rate higher than in modern OECD-style treaties.
Royalty rates under the China-Philippines treaty reflect its late-1990s vintage. Practitioners should confirm the rate against Article 12 for the specific royalty category.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–CN treaty
- TreatyGB–CN treaty
- TreatyCA–CN treaty
- TreatyAU–CN treaty
- TreatyCN–DE treaty
- TreatyCN–JP treaty
- TreatyCN–IN treaty
- TreatyCN–SG treaty
Primary sources
- China State Taxation Administration - tax treatiesVerified 2026-05-20
- Philippines Bureau of Internal Revenue - international taxVerified 2026-05-20
- OECD MLI signatories and partiesVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.