China's Newly Issued Guidelines on Determining "Beneficial Owners"

On October 27, 2009, China’s State Administration of Taxation issued a Circular on How to Understand and Determine “Beneficial Owners” Under Tax Treaties, providing technical guidance for China’s tax authorities to assess non-residents’ claims of treaty benefits with respect to China-sourced dividends, royalties and interest income. The Memorandum summarizes this Circular and its implications.