China's State Administration of Taxation (SAT) has published the synthesized texts of China's tax treaties with Georgia, Greece, Hungary, Iceland, Ireland, Israel, Japan, and Kazakhstan as impacted by the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent Base Erosion and Profit Shifting (MLI). The synthesized texts were prepared on the basis of the reservations and notifications submitted to the Depositary by the respective countries. The authentic legal texts of the treaty and the MLI take precedence and remain the legal texts applicable.
The MLI applies for the 2005 China-Georgia tax treaty:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023; and
- with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 March 2023.
The MLI applies for the 2002 China-Greece tax treaty:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023;
- with respect to all other taxes levied by China, for taxes levied with respect to taxable periods beginning on or after 1 March 2023; and
- with respect to all other taxes levied by Greece, for taxes levied with respect to taxable periods beginning on or after 1 January 2024.
The MLI applies for the 1992 China-Hungary tax treaty:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023;
- with respect to all other taxes levied by China, for taxes levied with respect to taxable periods beginning on or after 1 March 2023; and
- with respect to all other taxes levied by Hungary, for taxes levied with respect to taxable periods beginning on or after 1 January 2024.
The MLI applies for the 1996 China-Iceland tax treaty:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023;
- with respect to all other taxes levied by China, for taxes levied with respect to taxable periods beginning on or after 1 March 2023; and
- with respect to all other taxes levied by Iceland, for taxes levied with respect to taxable periods beginning on or after 1 January 2024.
The MLI applies for the 2000 China-Ireland tax treaty:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023; and
- with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 March 2023.
The MLI applies for the 1995 China-Israel tax treaty:
- in China:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023; and
- with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 March 2023;
- in Israel:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after the first day of the next taxable period that begins on or after 1 September 2022; and
- with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 January 2024.
The MLI applies for the 1983 China-Japan tax treaty:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023; and
- with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 March 2023.
The MLI applies for the 2001 China-Kazakhstan tax treaty:
- with respect to taxes withheld at source on amounts paid or credited to non-residents, where the event giving rise to such taxes occurs on or after 1 January 2023; and
- with respect to all other taxes, for taxes levied with respect to taxable periods beginning on or after 1 March 2023.
MLI synthesized texts of China's tax treaties can be found on the SAT's tax treaty webpage.