At an operational level, in contrast to China’s willingness to enter into new tax treaties, the PRC tax authorities have shown a clear propensity towards a more restrictive tax treaty interpretation and administration approach that, in practice, has served to limit foreign investors’ ability to access tax treaty benefits, explain Christopher Xing, Chris Ho and Roger Di.
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The new guidance is not meant to reflect a substantial change to UK law, but the requirement that tax advice is ‘likely to be correct’ imposes unrealistic expectations
China and a clutch of EU nations have voiced dissent after Estonia shot down the US side-by-side deal; in other news, HMRC has awarded companies contracts to help close the tax gap