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ARTICLE · 13 JULY 2026

Asia Tax Bulletin - Summer 2026

Mayer Brown
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This comprehensive bulletin examines critical tax developments across 12 Asian jurisdictions, including China's intensified scrutiny of Hong Kong holding company structures for dividend withholding tax benefits, Singapore's implementation of Pillar Two global minimum tax registration requirements, and India's new Income Tax Act taking effect.

GlobalTax
Pieter De Ridder
Pieter De Ridder
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We are pleased to present the Summer 2026 edition of the Asia Tax Bulletin, which provides the latest tax developments and insights across 12 Asian jurisdictions.

China (PRC)

Denial of tax treaty reduced dividend withholding tax rate

Chinese tax authorities are increasingly challenging cross-border dividend flows that rely on a reduced withholding tax rate under a tax treaty. This is especially true in respect of the China-Hong Kong tax arrangement to benefit from the preferential withholding enterprise income tax (WHT) rate of 5%. If a Hong Kong intermediary holding company is viewed as a conduit without real commercial substance, the Chinese authorities will deny treaty benefits.

Under China's Enterprise Income Tax Law, dividends paid by a PRC resident enterprise to a foreign shareholder are generally subject to 10% WHT. A reduced 5% rate may apply under the Tax Arrangement with Hong Kong provided that the foreign shareholder: (i) is a qualifying Hong Kong tax resident; (ii)

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This Mayer Brown article provides information and comments on legal issues and developments of interest. The foregoing is not a comprehensive treatment of the subject matter covered and is not intended to provide legal advice. Readers should seek specific legal advice before taking any action with respect to the matters discussed herein.

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