(Issued by the State Administration of Taxation on October 27 2009.)
(国家税务总局于二零零九年十月二十七日发布。)
Guo Shui Han [2009] No.601
国税函 [2009] 601号
Circular on How to Interpret and Recognise the “Beneficial Owner” in Tax Agreements
关于如何理解和认定税收协定中“受益所有人”的通知
The Circular states that conduit companies are not beneficial owners. It also sets forth factors that are not conducive to the recognition of an applicant's status as a beneficial owner.
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