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Denial of Tax Treaty Benefits for Dividend Distributions from China

|Approved Changes|China
China

In a recent decision by the tax authorities in Qinghai, China, an application for treaty benefits regarding a dividend distribution was denied on the basis that the non-resident recipient of the dividends failed China's beneficial ownership test.

The case involved a mining company in Qinghai that was 90% owned by an offshore holding company which was wholly owned by a parent company resident …

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