State Administration of Taxation, Circular on How to Interpret and Recognise the “Beneficial Owner” in Tax Agreements

国家税务总局关于如何理解和认定税收协定中“受益所有人”的通知

Conduit companies are not beneficial owners.

2 minute readDecember 08, 2009 at 11:58 PM

clpstaff

& clp articles

Issued: October 27 2009

Applicability: The term “beneficial owner” means a person who has ownership or control over income or the rights or property from which income is derived. Beneficial owners, in general, engage in substantive business activities and may be individuals, companies or any other entities

A Subscription is Required to Access this Content

Subscribe to China Law & Practice today for:

✓ A database of 3000+ essential documents, including key PRC laws translated into English
✓ Newsletters with business-critical and sector-specific updates
✓ Premium mobile access with timely analysis on China's fast-changing market

Already a Subscriber? Log In. Sign In Now

Questions? Contact us at [email protected] | 1-855-808-4530 (Americas) | 44(0) 800 098 386009 (UK & Europe)