The State Administration of Taxation (SAT) issued a ruling (Guo Shui Han [2009] No. 49 on 23 January 2009 confirming that dividends and interest paid by a resident enterprise to a qualified foreign institutional investor (QFII) are subject to 10% withholding tax unless an applicable tax treaty or tax arrangement provides otherwise. The paying resident enterprise is required to act as a withholding agent.
Implementation rules on special tax adjustments published – control…