In order to improve the implementation of double tax treaties between Mainland China and other tax jurisdictions, the State Administration of Taxation of Mainland China (“SAT”) released in February 2018 a Public Notice [2018] No. 9 (“Public Notice 9”), providing further and clearer guidelines/rules in assessing the Mainland China beneficial ownership (“BO”) status for the […]
As from 1 January 2018, Mainland China has introduced its first environmental tax law, the Environmental Protection Tax (the “EPT”) law. The EPT replaces the existing pollutant discharge fee (“PDF”) system, which was in operation for nearly the last 40 years. The main difference between the PDF and the EPT is that the former is […]
On 21 December 2017, the Chinese central government authorities issued a tax circular Caishui [2017] No. 88 (“Circular 88”) on China investment profits by foreign investors. According to Circular 88 and subject to conditions discussed below, foreign investors are allowed to defer payment of withholding tax on dividend income from equity investments in Chinese resident […]
Whether enough tax substance in a Trust is present will always depend on the relevant facts of the case.
