Originally Posted by
safelife
This might be true in your case, but not for others.
It is in no way applicable to my case, for example.
Agency in Austria, taxable in China, paid by the airline in China, 183 days rule does not apply (any more).
And so on. Each case is different, mostly depending on your home countries' rules.
To us article 15 means that only China can tax our income.
That's why I said that different countries have different tax treaties, Austria is known to deviate and as I gather in a positive way.
But this is what the model contract is, and most tax treaties follow the model.
Your home countries rules all depend on that countries tax treaty with CN, so yes there are variations, but the given example is how this one works out, not my home country btw.