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.
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While successful pillar two implementation will require collaboration across all units, a combination of internal and external tax advice is at the centre of the effort