Beneficial ownership gets international flavor in new overhaul

China leads the world in one area of lawmaking: the brevity of its legislation. Even a law as seemingly critical as the one that deals with the how interest, dividends and royalties due to non-tax resident companies or individuals are taxed, only takes up 1,658 words of the Chinese statute book. In other jurisdictions, a law such as the State Administration of Taxation, Announcement on Issues Relevant to the “Beneficial Owner” in Tax Agreements (SAT Announcement [2018] No.9, “Announcement 9”) (国家税务总局关于税收协定中“受益所有人”有关问题的公告) might run to hundreds of pages in a bid to cover every eventuality and deflect every loophole. At the same time, though the rules themselves may be brief, China has continued its pattern of tax policymaking of recent years by providing explanatory notes and guidance, as it seeks to learn from international policymaking practice.