Article 1 of the Enterprise Income Tax Law stipulates that within the territory of People's Republic of China (PRC), enterprises and other income-earning organizations (hereinafter referred to as enterprises) are taxpayers of enterprise income tax and shall pay enterprise income tax in accordance with the provisions of this Law.

Article 3 of the Regulations for the Implementation of the Enterprise Income Tax Law stipulates that the enterprises established in China according to law mentioned in Article 2 of the Enterprise Income Tax Law include enterprises, institutions, social organizations and other organizations established in China according to the laws and administrative regulations of China. According to the above provisions, under the new tax law, both private and public schools are corporate income tax payers.