Share with your friends

Definition of Beneficial Owner under Entrusted Investments

Definition of Beneficial Owner under Entrusted In...

Private Equity Tax Express - Issue 2, May 2014  


Related content

Definition of Beneficial Owner under Entrusted Investments

On 21 April 2014, the State Administration of Taxation (the “SAT”) released Announcement [2014] No.24 to clarify the definition of beneficial owner under “entrusted investments”. 

As a supplementary regulation to Guoshuihan [2009] No.601 and Announcement [2012] No.30 issued by the SAT in 2009 and 2012 respectively, the issuance of the new circular provides more detailed guidance to local tax authorities on how to determine the beneficial owner when non-residents invest in the PRC via entrustment with single- or multiple-layer collective investment structure.

However, given that Announcement 24 does not provide clear guidance on which collective investment scheme will be in scope while sets very strict requirements on documentation submission requirements, it is likely cause many practical issues during the implementation of this circular. 

© 2021 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  ("KPMG International"), a private English company limited by guarantee. All rights reserved. The KPMG name and logo are registered trademarks or trademarks of KPMG International.


For more detail about the structure of the KPMG global organisation please visit

Connect with us