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ILN Today Post

China Legal Update: Tax Treaty Beneficial Ownership Further Clarified by Chinese Tax Authority

In October 2009, the State Administration of Taxation (“SAT”) of the People’s Republic of China (“PRC”) issued Guoshuihan [2009] No. 601 (“Circular 601”), providing guidance on how to determine who is the beneficial owner (“BO”) of certain China sourced passive income under relevant bi-lateral tax treaties between China and foreign countries. However, issues and disputes have been arising in practice concerning the assessment of BO status during the implementation of Circulation 601. To address these concerns, the SAT recently released Public Notice [2012] No. 30 (“Public Notice 30”) to further clarify the application of Circular 601 and to provide administrative guidelines. Public Notice 30 took effect on June 29, 2012. More…More…

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