China Tax Alert - Issue 4, March 2015
On 4 March 2015 the Chinese State Administration of Taxation (SAT) issued interpretative guidance for the PRC-France double tax agreement (DTA), which entered into effect from 1 January 2015.
The PRC-France DTA interpretative guidance is a significant document may be viewed as shedding light on the general application of China’s numerous DTAs in relation to a number of complex matters. It gives an insight on how China is putting the work of the G20/OECD Base Erosion and Profit Shifting (BEPS) project into effect as well as providing guidance on the DTA treatment of transparent entities such as partnerships and collective investment vehicles (CIVs) and clarifying the use of China’s anti-treaty shopping rules.
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