A case study analysing the new “same jurisdiction/same treaty benefit rule” when applying DTA benefits to avail lower tax rates for dividend repatriation.
In the first article of this issue, we look at the evolution of the legal framework of double taxation agreements in China, including the foundations of anti-avoidance, obligations in reporting offshore transactions, how to qualify as a beneficial owner and how to claim treaty benefits. In the next article, we outline the interpretations given in Circular 75 of the China-Singapore DTA, which was the first time that the Chinese tax authorities really opened up about DTA interpretations.
China recently released Circular 30, aiming to avoid double-taxation and appropriately reduce tax burdens by clarifying the determination of beneficial ownership.
China’s double tax agreement with Syria – which specifies the definition of a permanent establishment, lists the taxation on different types of incomes, and clarifies the exchange of tax information – will apply to incomes obtained by both countries’ residents from January 1, 2012.