Generally speaking, contract management is a business form in which the enterprise is contracted out to other units or individuals, and the contractor engages in business in the name of the employer or in its own name, and the contracting income of the employer is directly related to the contracted business results. For example, enterprise A entrusts enterprise B to be responsible for contracting operation, and both parties agree in the contract that enterprise B will still operate in the name of enterprise A after contracting, and the after-tax profit of enterprise A will be shared by both parties. This operation mode belongs to contract management.

Paragraph 1 of Article 49 of the Detailed Rules for the Implementation of the Law on the Administration of Tax Collection in People's Republic of China (PRC) (the State Council Order [2002] No.362) stipulates that if the contractor and lessee have the right to independent production and operation, conduct independent financial accounting, and pay the contract fee or rent to the employer and lessor on a regular basis, the contractor and lessee shall pay taxes on their production, business income and income and accept tax administration; However, unless otherwise provided by laws and administrative regulations.

Paragraph 2 of Article 49 of the Detailed Rules for the Implementation of the Law of People's Republic of China (PRC) Municipality on the Administration of Tax Collection (the State Council Order [2002] No.362) stipulates that the employer or lessor shall report the relevant information of the contractor or lessee to the competent tax authorities within 30 days from the date of spontaneous contracting or leasing. If the employer or lessor fails to declare, the employer or lessor and the contractor or lessee shall bear joint and several liability for tax payment.

Article 1 of the Notice of State Taxation Administration of The People's Republic of China, People's Republic of China (PRC) on Taxing Income from Contracted Operation and Leased Operation of Enterprises and Institutions by Individuals (Guo Shui Fa [1994]No. 179) stipulates that "after an enterprise implements contracted operation and leased operation by individuals, if the industrial and commercial registration is still an enterprise, regardless of its distribution method, enterprise income tax shall be paid first according to the relevant provisions of enterprise income tax." Article 2 stipulates that "if an enterprise changes its industrial and commercial registration to individual industrial and commercial households after individual contracting and leasing operations, individual income tax shall be levied according to the articles obtained by individual industrial and commercial households, and enterprise income tax shall not be levied."

According to the above provisions, when determining the enterprise income tax payer, we only need to consider whether the relevant business entities belong to independent enterprise legal persons, and do not need to consider the contracting and leasing situation.