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HMRC internal manual

Double Taxation Relief Manual

From
HM Revenue & Customs
Updated
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Guidance by country: China: dividends

Dividends are taxable in China at a rate not exceeding 5% where the United Kingdom beneficial owner is a company which holds directly at least 25 per cent of the Chinese company paying the dividend (unless this company is a property investment company).

Where the dividend is a qualifying dividend paid out of the property income of an investment vehicle equivalent to a United Kingdom Real Estate Investment Trust, dividends are taxable in China at a rate not exceeding 15%.

Dividends paid by Chinese companies to the United Kingdom government or any entity wholly owned by it are exempt from tax in China.

In all other cases, dividends paid by Chinese companies and beneficially owned by United Kingdom residents are taxable in China at a rate not exceeding 10%.

Where the dividend is effectively connected with a permanent establishment which the United Kingdom resident recipient has in China, the provisions of Article 7 will apply.