February 2018 - Beneficial Ownership – Further Guidance From China Tax Authority

In order to be able to enjoy tax treaty benefits with China, the taxpayer must be a tax resident of the jurisdiction which has entered into the tax treaty with China. In addition, in order to obtain a preferential treatment on dividends, interest, and royalties from China, the non-resident must also be the “Beneficial Owner” of such income.

Since 2009, the State Administration of Taxation (‘SAT”) has issued several circulars to assist in the determination of “Beneficial Ownership” (“BO”) status.


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