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Circular 165: China’s Most Recent Guidance Concerning the Meaning of “Beneficial Owner”

Since the Enterprise Income Tax Reform in 2008, Chinese tax authorities have been increasing their scrutiny of cross-border transactions and have been challenging the perceived abusive use of holding structures and other offshore tax arrangements. One of the areas which Chinese tax authorities have been focusing on is whether the offshore recipient of dividends, interest, and royalties from mainland Chinese enterprises is, in fact, the “beneficial owner” thereof under China’s double tax treaties or arrangements (“DTAs”).