A tax circular which seeks to strengthen the administration of tax on income derived from equity transfer may have a profound impact on non-resident investors using offshore vehicles. But the authorities have some legal hurdles to clear
The Circular sets forth the criteria under which a venture investment enterprise may enjoy tax reduction for investment in an unlisted small or medium high and new technology enterprise.
A new tax circular addresses the issue of the definition of a beneficial owner under tax treaties, and puts a new burden on taxpayers. But many issues are left unclarified
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.