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Tax Analysis


P170/2012 - 24 July 2012

SAT clarifies determination of "Beneficial Owner" under China’s Tax Treaties and introduces  "Listed Company Safe Harbour" for Dividends

The PRC State Administration of Taxation (SAT) issued guidance on 29 June 2012 addressing a number of issues relating to the determination of the "beneficial owner" of income under China’s tax treaties and tax arrangements (Bulletin of the SAT [2012] No. 30).  Shortly thereafter, the SAT published explanatory notes concerning its position on the issues covered by Circular 30.  The circular is effective as from the date of issuance.

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