The State Administration of Taxation (SAT) issued a ruling (Guo Shui Han [2009] No. 49 on 23 January 2009 confirming that dividends and interest paid by a resident enterprise to a qualified foreign institutional investor (QFII) are subject to 10% withholding tax unless an applicable tax treaty or tax arrangement provides otherwise. The paying resident enterprise is required to act as a withholding agent. Implementation rules on special tax adjustments published – controlled foreign corporations The State Administration of Taxation (SAT) issued the implementation rules on special tax adjustments on 9 January 2009 (Guo Shui Fa [2009] No.2). The rules...