China Tax Alert - Issue 29, October 2013
The State Administration of Taxation (SAT), after consultation and agreement with the Hong Kong Inland Revenue Department (IRD), issued Announcement 53 to simplify the procedures used when Hong Kong tax resident companies and individuals apply for tax treaty relief under the Double Tax Arrangement between the PRC and Hong Kong (PRC-HK DTA). Announcement 53, which will become effective on 1 November 2013, is a welcome development as it alleviates the need for a tax residency certificate (TRC) to be produced by Hong Kong residents at the outset of the DTA application — although, ultimately, a TRC may still be needed if the tax authorities have any doubts regarding the applicant’s residency status. This places Hong Kong companies and individuals at a comparative advantage over applicants from other jurisdictions, who are required to produce a TRC as matter of course, in complying with DTA applications procedures under Circular 124.
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