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Chinese Tax Authorities Issue Practice Guidance on Implementing the China- Singapore DTA

As part of an overall process to streamline the interpretation and application of tax treaties entered into by mainland China with other jurisdictions, the State Administration of Taxation (SAT) recently issued on 26 July 2010 a tax circular, Guoshuifa [2010] No. 75 (Circular 75), on the interpretation of the Double Tax Agreement between the People’s Republic of China and Singapore (China-Singapore DTA). Although Circular 75 is a unilateral interpretation and practice guideline issued by the SAT with respect to implementing the China-Singapore DTA, it is also the first set of comprehensive guidelines the SAT has issued for the interpretation of treaties. Its significance is that it applies not only to the China-Singapore DTA but also to any other DTA that China has concluded, with provisions that are consistent with those of the China-Singapore DTA. In addition, Circular 75 prevails over any previous interpretive circular on DTAs in cases of conflict or inconsistency with regard to any specific treaty provisions.