“Beneficial Ownership – Further Guidance From Mainland China Tax Authority” – A Plus Magazine (March 2018)

Anthony Tam, Executive Director of Tax Services and Barbara Siu, Tax Manager at Mazars Hong Kong, were featured in the March 2018 issue of the A Plus Magazine. In the article, Anthony and Barbara analyse the new guidelines determining a beneficial owner qualification under dividends, interest and royalties articles of tax treaties.

On 3 February, the State Administration of Taxation (SAT) released Public Notice [2018] No. 9 (PN 9) on determining the beneficial owner of receiving dividends, interest and royalties from Mainland China when applying the preferential treatment of such income.

Prior to PN 9, the SAT had issued several circulars to assist in the determination of “Beneficial Ownership” status since 2009.


To read the full article, please see the PDF attached below or click here.

Credits: Anthony Tam and Barbara Siu for A Plus magazine, March 2018 issue


Beneficial ownership – further guidance from Mainland China tax authority - A Plus Magazine (March 2018)