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China | MLI will be applicable to certain payments as of 1 January 2023

17 November 2022

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Tax Alerts, National/Federal Taxation, T...

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China

The Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting became effective for China on 1 September 2022.In anticipation of the changes to the existing China tax treaties as early as January 2023, multinational enterprises should act with extra caution when entering a specific arrangement or transaction, especially the principal purpose test which may lead to denial of treaty benefits.China’s State Taxation Administration (STA) released STA Public Notice [2022] No. 16 (PN 16) on 1 August 2022 to clarify certain matters related to the entry into force of the Multilateral Convention to Implement Tax...