Foreign companies could be caught in China's new indirect transfer rules

International Tax Review is part of Legal Benchmarking Limited, 1-2 Paris Garden, London, SE1 8ND

Copyright © Legal Benchmarking Limited and its affiliated companies 2026

Accessibility | Terms of Use | Privacy Policy | Modern Slavery Statement

Foreign companies could be caught in China's new indirect transfer rules

china-flag-100px.png

In a strong indication of its growing commitment to enforcing tax compliance, China’s State Administration of Taxation released updated indirect transfer rules to replace Notice 698. Tax professionals say the more stringent tax rules, which include safe harbour regulations, withholding tax obligations of the buyer, and clarifications of reasonable commercial purpose, are both welcome and concerning.

Unlock this content.

The content you are trying to view is exclusive to our subscribers.

To unlock this content:

Take a Free Trial or Login
more across site & shared bottom lb ros

More from across our site

Exclusive ITR data emphasises that DEI does not affect in-house buying decisions – and it’s nothing to do with the US president
The firms made senior hires in Los Angeles and Cleveland respectively; in other news, South Korea reported an 11% rise in tax income, fuelled by a corporation tax boom
The ‘deeply flawed’ report is attempting to derail UN tax convention debates, the Tax Justice Network’s CEO said
Salim Rahim, a TP specialist, had been a partner at Baker McKenzie since 2010
While the manual should be consulted for any questions around MAPs, the OECD’s Sriram Govind also emphasised that the guidance is ‘not a political commitment’
The landmark Indian Supreme Court judgment redefines GAAR, JAAR and treaty safeguards, rejects protections for indirect transfers and tightens conditions for Mauritius‑based investors claiming DTAA relief
The expansion introduces ‘business-level digital capabilities’ for tax professionals, the US tax agency said
As tax teams face pressure from complex rules and manual processes, adopting clear ownership, clean data and adaptable technology is essential, writes Russell Gammon, chief innovation officer at Tax Systems
Partners want to join Ryan because it’s a disruptor firm, truly global and less bureaucratic, Tom Shave told ITR
If Trump continues to poke the world’s ‘middle powers’ with a stick, he shouldn’t be surprised when they retaliate
Gift this article