International treaty

2013 UK-China Protocol to the 2011 Agreement — in force

Updated 28 August 2025

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This publication is available at https://www.gov.uk/government/publications/china-tax-treaties/2013-uk-china-protocol-to-the-2011-agreement-in-force

Protocol amending the double taxation agreement between the United Kingdom and the People’s Republic of China.

The Protocol to the double taxation agreement between the UK and China, signed in Beijing on 27 February 2013, entered into force on 13 December 2013.

  1. The provisions of this Protocol shall have effect:
  2. a) in China, in respect of profit, income and capital gains arising in any tax year beginning on or after 1st January 2014;
  3. b) in the United Kingdom,
    1. (i) in respect of income tax and capital gains tax, for any year of assessment beginning on or after 6th April 2014;
    2. (ii) in respect of corporation tax, for any financial year beginning on or after 1st April 2014.

HM Revenue & Customs December 2013.

Protocol amending the agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the people’s Republic of China for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital gains

The Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the People’s Republic of China,

Desiring to amend the Agreement between the Government of the United Kingdom of Great Britain and Northern Ireland and the Government of the People’s Republic of China for the avoidance of double taxation and the prevention of fiscal evasion with respect to taxes on income and on capital gains signed at London on 27 June 2011 (hereinafter referred to as ‘the Agreement’),

Have agreed as follows:

Article 1

Sub-paragraph a) of paragraph 2 of Article 10 of the Agreement shall be deleted and replaced by the following:

  1. ‘a) 5 per cent of the gross amount of the dividends if the beneficial owner is a company which holds directly at least 25 per cent of the capital of the company paying the dividends;’

Article 2

Each of the Contracting States shall notify the other, through diplomatic channels in writing, of the completion of the procedures required by its law for the bringing into force of this Protocol. This Protocol shall enter into force on the date of the later of these notifications and shall thereupon have effect in accordance with paragraph 1 of Article 28 of the Agreement.

IN WITNESS WHEREOF the undersigned, duly authorised thereto, have signed this Protocol.

DONE at Beijing on the 27th day of February 2013, in duplicate in the Chinese and English languages, both texts being equally authoritative.

For the Government of the United Kingdom of Great Britain and Northern Ireland: Sebastian Wood

For the Government of the People’s Republic of China: Wang Li

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