Our collection of resources based on what we have learned on the ground
Resources
Q&A
What is the most common difficulty for Hong Kong clients when applying to avail ...
- September 2012
- Members Access
The most common difficulty for our clients in Hong Kong when applying to avail of treaty benefits under DTAs between China and other countries is to obtain the tax resident certificate for their Hong Kong entity, especially when the Hong Kong en...
Q&A
Have the Double Taxation Avoidance Agreements (DTA) become more stringent and sp...
- September 2012
- Free Access
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, t...
Q&A
What is a permanent establishment (PE)?
- September 2012
- Free Access
A permanent establishment (PE) can be a place of management, a branch, an office, a factory, etc. or certain activities, such as a building site or construction project or rendering of consultancy services that last over a specified time (stipulated ...
Q&A
What types of categories are tax treaties divided into?
- September 2012
- Members Access
The United Nations Conference on Trade and Development divides tax treaties into categories based on their applicability, primarily on their income, income and capita, protocol and transportation (air, water, or both).
Q&A
What happens when investors are subject to two different tax systems?
- September 2012
- Members Access
Confusion about international taxation can arise when investors are subject to two different and potentially conflicting tax systems. For example, Hong Kong and Singapore adopt a “territorial source” principle of taxation, which means tha...
Q&A
What is Double Taxation Avoidance (DTA) ?
- September 2012
- Free Access
Double Taxation avoidance agreements aim to prevent the same income from taxation by two or more states, while also eliminating tax evasion and encouraging cross-border trade efficiency.
Q&A
What are the taxes covered under the Double Taxation Agreement (DTA) between Chi...
- September 2012
- Free Access
According to Article 2 of the DTA, the taxes covered are individual income tax (IIT) and corporate income tax (CIT) in China, income tax in singapore and according to Circular 75, these taxes can be levied directly by the government or withheld at so...
Q&A
Can an ?agent of independent status? operating on behalf of an enterprise of one...
- September 2012
- Members Access
According to the Article 5 of the DTA, an “agent of an independent status” acting in the ordinary course of their business will not be deemed to be a PE. Circular 75 provides that the activities of an agent should meet the below two crit...
Q&A
Will income derived by a resident of a Contracting State from immovable property...
- September 2012
- Members Access
Will income derived by a resident of a Contracting State from immovable property situated in the other Contracting State be taxed in that other State (China and Singapore DTA Agreement)?
Q&A
In which case are the business profits of an enterprise in one Contracting State...
- September 2012
- Free Access
According to Article 7 of the DTA, the profits of an enterprise of a Contracting State can be taxed in the other Contracting State when the enterprise carriers on business in the latter through a PE situated therein. In this case, the profits of the ...
Q&A
How will dividends paid by a company resident in a Contracting State to a reside...
- September 2012
- Members Access
According to Article 10 of the DTA, if the beneficial owner of the dividends is a resident of the other Contracting State, the tax should not exceed: 5% of the gross amount of the dividends if the beneficial owner is a company (other than a partne...
Q&A
What is the situation in China for foreign companies wishing to obtain Double Ta...
- September 2012
- Members Access
The determination of beneficial owner requires the disclosure of a good amount of business information, including information about the number of employees, information about revenue, and so on. In addition, there is always the possibility tha...
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