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HMRC internal manual

Double Taxation Relief Manual

HM Revenue & Customs
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Guidance by country: China: residence of companies

Article 4 of the Agreement contains rules for determining the residence of companies for the purposes of the Agreement. These generally follow the pattern of the OECD Model (see INTM152040). Therefore, where a company is a resident of both countries by virtue of Article 4(1), it is to be treated for the purposes of the Agreement as a resident of the country in which its place of effective management is situated. Unlike, the previous agreement (SI1984/1826), this agreement does not contain the provision that where the place of effective management is in one country and the place of its head office is in the other country, the two countries have to settle the country of residence by mutual agreement.