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Treaty treatment of royalties clarified

|Approved Changes|China (People's Rep.)
China (People's Rep.)

On 14 September 2009, the State Administration of Taxation (SAT) issued Guoshuihan (2009) No. 07 (the Circular) to clarify the tax treaty treatment of royalties (including under the China-Hong Kong and China-Macau tax arrangements). The Circular, which takes effect on 1 October 2009, summarizes the tax treaty treatment of royalties as follows:

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