On March 29, 2011, the State Administration of Taxation (“SAT”) issued a circular (Public Notice [2011] No.24) to clarify the taxation of certain income (mainly passive income) derived in China by non-tax resident enterprises (“Non-TREs”), including accrued payments due to Non-TREs, guarantee fees, capital gains from the transfer of land use rights in China, rental from financial leases or leases of immovable property in China, dividends and profi t distributions, etc. It also clarifi es a few unclear issues in a previous circular (Guoshuihan[2009] No.698) which addresses various issues on direct and indirect transfer of equity in a Chinese enterprise by Non-TREs.