Article 7 of the Regulations for the Implementation of the Enterprise Income Tax Law stipulates that the income from sources inside and outside China mentioned in Article 3 of the Enterprise Income Tax Law shall be determined according to the following principles:

The income from providing services shall be determined according to the place where the services occur.

According to the above provisions, if the labor service of an overseas company occurs overseas, it shall be determined as overseas income according to the above principles and the place where the labor service occurs;

If the company is a non-resident as stipulated in the third paragraph of Article 3 of the Enterprise Income Tax Law: "If a non-resident enterprise has no institution or place in China, or has an institution or place, but its income has no actual connection with its institution or place, it shall pay enterprise income tax on its income originating in China.