Have the Double Taxation Avoidance Agreements (DTA) become more stringent and specific for foreigners after 2010 in China?

Beginning in 2010, stronger, more specific regulations began to come into effect, and companies began to have to apply for relief under DTAs; for example, in order to qualify for DTA relief from withholding tax on dividends, interest and royalties, the State Administration of Taxation (SAT) needs to assess if a company in the DTA partner jurisdiction (for example, Hong Kong or Singapore) is indeed considered a ‘beneficial owner’ of the Chinese subsidiary.