Legal analysis: According to relevant laws and regulations, royalties paid between business units within an enterprise shall not be deducted before tax. Since the Enterprise Income Tax Law adopts corporate income tax, enterprise branches are part of the enterprise's head office and are not an independent entity. They cannot become independent corporate income tax taxpayers. They should be consolidated and paid by a unified representative of the enterprise's head office.

Legal basis: Article 49 of the "Regulations on the Implementation of the Enterprise Income Tax Law of the People's Republic of China" Management fees paid between enterprises, rents and franchises paid between business units within the enterprise Fees and interest paid between business entities within non-bank enterprises are not deductible.