the domestic factory pays the overseas parent company the trademark use fee, and the trademark use contract has been registered, which is used for all the goods exported and sold by the factory, and the corresponding taxes have been withheld and remitted when paying the use fee.

when calculating the enterprise income tax, article 8 of the regulations for the implementation of the enterprise income tax law

stipulates that the reasonable expenses actually incurred by an enterprise, including costs, expenses, taxes, losses and other expenses, are allowed to be deducted when calculating the taxable income.

article 41 (1) stipulates that if the business dealings between an enterprise and its related parties do not conform to the principle of independent transactions, and the taxable income or income of the enterprise or its related parties is reduced, the tax authorities have the right to make adjustments in a reasonable way.

article 47 stipulates that if an enterprise reduces its taxable income or income by implementing other arrangements that have no reasonable commercial purpose, the tax authorities have the right to make adjustments in a reasonable way.

article 111 of the regulations for the implementation of the enterprise income tax law stipulates that the reasonable methods mentioned in article 41 of the enterprise income tax law include:

(1) the comparable uncontrolled price method refers to the method of pricing according to the prices of the same or similar business transactions between unrelated parties;

(2) resale price method refers to the method of pricing by deducting the gross sales profit of the same or similar business from the price of goods purchased from related parties and resold to unrelated parties;

(3) Cost additive process refers to the method of pricing according to cost plus reasonable expenses and profits;

(4) the transaction net profit method refers to the method of determining profits according to the level of net profit obtained by unrelated parties in the same or similar business dealings;

(5) the profit division method refers to the method of distributing the consolidated profits or losses of an enterprise and its related parties among all parties by adopting reasonable standards;

(6) other methods that conform to the principle of independent trading.

according to the above regulations, domestic factories and overseas parent companies are related parties, and their payment of trademark use fees to overseas parent companies conforms to the principle of independent transactions, and has reasonable business purpose arrangements, and reasonable expenses related to the income earned by domestic factories can be deducted before the income tax of domestic factories. Otherwise, the tax authorities have the right to make adjustments in a reasonable way.