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 OECD had previously missed a June 30 deadline to agree an MLC on amount A; in other news, UK corporation tax bills surged to a record high last year