China: New withholding tax administrative guidance - KPMG Global
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China: New withholding tax administrative guidance

China: New withholding tax administrative guidance

China’s State Administration of Taxation (SAT) issued new guidance on withholding tax administration.


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The guidance—SAT Announcement [2017] No. 37 (17 October 2017) and “official interpretative guidance”—

  • Withdraws certain withholding tax document registration requirements
  • Clarifies the withholding tax calculations for disposal gains
  • Introduces more reasonable timeframes for withholding tax payments
  • Clarifies the withholding tax obligations of agents and overseas payment recipients

KPMG observation

The clarifications in Announcement 37 generally are viewed favourably by industry. However, there are areas of uncertainty concerning the precise obligations of withholding tax agents and overseas payment recipients, as well as uncertainties regarding the operation of the amended withholding tax compliance timeframes. Particular challenges are presented in reconciling Announcement 37 to the indirect offshore disposal rules in SAT Announcement [2015] No. 7.


Read a November 2017 report prepared by the KPMG member firm in China

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