The Concept of “Beneficial Ownership” in China’s Tax Treaties – The Current State of Play

Journal
China (People’s Rep.)
Bulletin for International Taxation 2013 (Volume 67), No. 2
This article considers the “problems” that have arisen regarding the practical implementation of China’s rules on the concept of “beneficial ownership” (Circular 601 [2009]). In this context, relevant administrative rulings and the recently issued “clarification” by the State Administration of Taxation in Bulletin 30 [2012] are specifically examined.