The pending protocol to the 1991 tax treaty between Austria and China was signed on 14 September 2023. The protocol is the first to amend the treaty and includes the following changes:
- The title of the treaty is replaced in line with BEPS standards;
- Article 1 (Persons Covered) is replaced, including a new provision that income derived by or through an entity or arrangement that is treated as wholly or partly fiscally transparent under the tax law of either Contracting State shall be consider…