Presentation of the 'Beneficial Owner' Rule and Its Application in International Anti-tax Avoidance

摘要

With the development of global international exchanges and international trade, China has officially signed more than 100 tax treaties to avoid international double taxation. These tax treaties are conducive to the introduction of foreign capital and the development of foreign trade, but it is accompanied by an increasingly serious international tax avoidance issue. To this end, the "beneficial owner" rule in the anti-tax avoidance clause has become the focus of the practice community.