China's State Administration of Taxation has issued Notice No. 9 of 2018 and the related interpretation guidance on the determination of beneficial ownership and eligibility for tax treaty benefits with respect to dividend, interest, and royalty payments.
General Guidance on Beneficial Owner Status Determination
Notice No. 9 includes that "Beneficial Owner" means a person who has ownership and control over the rights or property from which the income is derived. In determining beneficia…