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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(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
Offices of the State Administration of Taxation and local taxation bureaux of provinces, autonomous regions, municipalities directly under the central government and cities with independent development plans and Yanghzou Tax Institute:
各省、自治区、直辖市和计划单列市国家税务局、地方税务局，扬州税务进修学院：
Pursuant to relevant provisions of agreements on the avoidance of double taxation entered into