The State Administration of Taxation (SAT) issued a ruling (Guo Shui Hu [2009] No. 81) on 20 February 2009 providing the tax offices with guidance on the implementation of the treaty article on dividends. The ruling does not mention the date of its application; however, it is generally assumed that the ruling applies from 1 January 2008. The content of the ruling is summarized below. According to the ruling, in order to obtain the benefits provided under the article on dividends of a tax treaty, a taxpayer must satisfy the following conditions: -   the taxpayer must be a resident...