legal ground
Article 3 of the Regulations for the Implementation of the Individual Income Tax Law of the People's Republic of China
Unless otherwise stipulated by the competent departments of finance and taxation of the State Council, the following income, regardless of whether the place of payment is within the territory of China, comes from China:
(3) Income from licensing various franchises for use in China.
Article 6
Personal income range stipulated in the individual income tax law:
(4) Income from royalties refers to income obtained by individuals from providing patents, trademarks, copyrights, the right to use non-patented technologies and other franchises; The income from providing the right to use copyright does not include the income from remuneration.