On 22 October 2019 the STA released new DTA administrative guidance in Announcement 35. This will take effect from January 2020 and replaces the existing guidance in Announcement 60.

The new guidance is in line with a broader government program to reduce regulatory burdens and red tape for businesses, and moves China further in the direction of a full self-assessment based tax system. The potential tax exposures for withholding tax (WHT) agents are also reduced, and may allow for more DTA relief to be granted upfront. However, significant ambiguities remain.