The State Administration of Taxation (SAT) issued a ruling on 27 October 2009 (Cai Shui Han [2009] No. 601) instructing how "beneficial owner" is determined for the purposes of treaty articles on dividends, interest and royalties. The content of the ruling is summarized below.
"Beneficial owner" is referred to as a person who is in possession of and has power to dispose of the income or the right to income and assets. A beneficial owner is generally supposed to carry on …