Deloitte: Tax Analysis – Interpretation of China-Singapore Tax Treaty and Protocol (III) – Guidance on the Application of Dividend, Interest, Royalties and Capital Gains Articles

Sep 30, 2010 | Corporate Member News

As explained in our earlier Tax Analyses (dated 13 and 21 September 2010), the Chinese State Administration of Taxation (“SAT”) recently released the first detailed guidance on the interpretation of the 2007 China-Singapore tax treaty and protocol, Guo Shui Fa [2010] No. 75 (“Circular 75”).  Circular 75 also applies to any similar provisions in China’s other tax treaties/arrangements, and supersedes any previous interpretations that are inconsistent with Circular 75.  Circular 75 therefore should be regarded as general guidance on tax treaty issues in practice.

This Tax Analysis focuses on the key issues relating to the dividends and capital gains articles.  The SAT’s interpretations in Circular 75 on the interest article are generally consistent with the guidance provided in the Commentaries to the OECD Model Convention and those on the royalties article are consistent with previous SAT guidance (Guo Shui Han [2009] No. 507). 

Please click here for details in English and here for details in Chinese.

Should you have any questions please contact Jay Niederhoffer in Toronto at 416-601-6277, Joyce Lee in Vancouver at 604-640-3092, Tan Ong in Montreal at 514-393-5529 or Charles Evans in Edmonton at 780-421-3884. 

Tax Analysis is published for the clients and professionals of the Hong Kong and Chinese Mainland offices of Deloitte Touche Tohmatsu. The contents are of a general nature only. Readers are advised to consult their tax advisors before acting on any information contained in this newsletter. Please click here to view the back issues.

To help you stay sharp to all the latest issues and strategies, we also encourage you to register for Asia Pacific Dbriefs / China Dbriefs, which is the live webcasts that provide valuable insights on important tax developments affecting your business in Asia Pacific. For more details, please visit


Loretta Yuen
Director | Chinese Services Group
Address, 121 King street West, Suite 300, Toronto, Ontario, M5H 3T9, Canada
Tel/Direct 416-601-6222 | Fax 416-601-6151 | Mobile 416-577-2787
[email protected] |      

About The Chinese Services Group
The Canada Chinese Services Group (CSG) of Deloitte & Touche LLP co-ordinates with the Deloitte Touche  Tohmatsu Limited member firm in China and the appropriate subsidiary of Deloitte & Touche LLP to assist Canadian companies investing and operating in China. Whether contemplating market entry, M&A or optimization of existing operations, the CSG, in collaboration with the member firm in China, can help Canadian companies implement cross-border investment strategies and navigate the associated risks.

The CSG also co-ordinates with the China Member firm and the appropriate subsidiary of Deloitte & Touche LLP to assist Chinese companies seeking to access North American markets – expanding operations, raising capital and/or engaging in M&A. Our national network of bilingual professionals works closely with colleagues in China to deliver seamless service to globalizing Chinese companies.

For more information about the Canada Chinese Services Group, please visit our website at or email to [email protected].

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