China Tax Alert - Issue 10, May 2013
A circular issued by the State Administration of Taxation (SAT) provides some guidance on the assessment of beneficial ownership of dividends under the PRC-HK double tax arrangement (PRC-HK DTA) for the purposes of withholding tax relief. This circular has confirmed the position put forward in Circular 601 and Announcement 30 that a “totality of facts” approach be adopted in assessing the beneficial owner status of a non-resident enterprise in relation to dividends derived from China.
© 2021 KPMG KPMG Huazhen LLP, a People's Republic of China partnership, KPMG Advisory (China) Limited, a limited liability company in China, KPMG, a Macau partnership and KPMG, a Hong Kong partnership, are member firms of the KPMG global organisation of independent member firms affiliated with KPMG International Limited, a private English company limited by guarantee. All rights reserved.
The KPMG name and logo are trademarks used under license by the independent member firms of the KPMG global organisation.
For more detail about the structure of the KPMG global organisation please visit https://home.kpmg/governance.