Mainland China and Hong Kong have entered into their Fifth Protocol to their Comprehensive Avoidance of Double Taxation Arrangement.
One can potentially enjoy a significant withholding tax saving on the distribution/payment of dividends, interests or royalties from out of Mainland China by applying the Mainland China DTAs, subject to certain conditions.
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 […]
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 […]