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
SAT clarifies deed tax calculation for leasehold grant.
Three types of items not treated as royalties.
Conduit companies are not beneficial owners.
China consolidates rules on tax reduction eligibility of non-tax-residents.
Venture investment companies may enjoy tax reduction.
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 clarifies the amounts or remuneration that shall not be treated as royalties but rather as income derived from service activities.
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.