China: Tax Treaties

Global regulatory frameworks are rapidly evolving to enhance transparency around offshore wealth structures through beneficial ownership registration regimes and enhanced corporate disclosure requirements. As tax authorities gain unprecedented access to information about ultimate controllers and economic beneficiaries behind complex offshore entities, individual investors face increasing scrutiny of their cross-border investment arrangements and compliance obligations.

On September 1, 2026, the Ministry of Finance and the State Taxation Administration jointly issued the Announcement on Individual Income Tax Policies Concerning Dividends and Profit Distributions Received by Foreign Individuals (Announcement [2026] No. 27 of the Ministry of Finance and the State Taxation Administration, hereinafter referred to as “Announcement No. 27”), introducing significant changes to the individual income tax treatment of dividends and profit distributions received by foreign individuals from foreign invested enterprises (“FIEs”). Announcement No. 27 took effect upon issuance.

This comprehensive bulletin examines recent tax developments across Asia, including China's VAT reforms, India's controversial Supreme Court ruling on treaty protection, Japan's 2026 tax reform package...

This paper will focus on Article 16 - mutual agreement procedure (the MAP) and will be organized in the following way:

As the following table shows, a Signatory or Party to the Convention can choose to apply paragraph 4 either in addition to or to the exclusion of paragraph 1.

Both Japan and Zealand opts in for Article 9(4), and both of the two contracting states have made notification to the Depositary, pursuant to Article 9(8) of the MLI.

Since the last update, a number of tax regulations in China have been updated due to changes in government policy.

A number of tax regulations in China have been updated due to changes in government policy.

On 4 November 2010, the PRC State Administration of Taxation and the Ministry of Finance jointly issued the Tax Circular Caishui [2010] No. 103 to levy City Maintenance and Construction Tax ("CMCT") and Education Surcharge also on foreign enterprises, foreign invested enterprises and foreign individuals.