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Tax Analysis

SAT issues guidance on beneficial ownership of dividends under tax arrangement with Hong Kong


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P180/2013 - 8 May 2013

China’s State Administration of Taxation (SAT) issued guidance on 12 April 2013 (Shuizonghan  [2013] No. 165 (Circular No. 165)) in response to enquiries from various provincial and city SAT offices as to whether certain Hong Kong companies should be regarded as beneficial owners of dividends received for purposes of the tax arrangement between Mainland China and Hong Kong. Although Circular No. 165 is addressed to the relevant local SAT offices, the guidance is expected to be followed generally by all tax authorities in China with respect to the application of similarly worded dividends articles in China's other tax treaties.

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