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Title: Beneficial ownership in China's corproate income tax regim
Authors: Chan, S
Cheung, D
Issue Date: 2013
Source: The International tax journal, 2013, v. 39, no. 2, p. 35-42
Abstract: By July 2012, China had entered into 99 double tax agreements and signed nine tax information exchange agreements with Argentina, Bahamas, Bermuda, BVI, Cayman Islands, Guernsey, Isle of Man, Jersey and San Marino. On Oct 27, 2009, the Chinese tax authorities issued Guoshuihan (2009) No. 601 -- Interpretation and Determination of "Beneficial Owner" under Tax Treaties (Circular 601) to provide clearer guidance on how to determine whether a nonresident applicant qualifies as the "beneficial owner" of China sourced income for the purposes of obtaining treaty relief. However, it did not completely achieve its original purposes because there were still many grey areas and controversies in implementing the operational guidelines in Circular 601. This article provides an update on the interpretation and determination of "beneficial owner" under tax treaty in China's corporate income tax system.
Publisher: CCH Inc.
Journal: The International tax journal 
ISSN: 0097-7314
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