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    Changes to double tax treaty between China and India

CHINA - Changes to double tax treaty between China and India

August 2019

Amendments to the double tax treaty between China and India were signed off on the 26 November 2018 and came into effect on the 5 June 2019. The agreement applies to all taxation from the 1 January 2020 in China and 1 April 2020 in India.

Main changes

Persons covered

Further provisions on the taxation of income received via fiscally transparent entities.


Where you are a dual resident there are additional provisions to decide where you are ultimately resident for double tax treaty purposes

Permanent establishment

Changes relating to the time periods reviewed regarding permanent establishments in construction engineering and services projects.

Business profits

Reviewing how business profits are attributed to permanent establishments and which country has the taxing rights on these.


Clarification on the definition of ‘Central Bank’ in both countries being the People’s Bank of China and the Reserve Bank of India.

Gordon Gao
[email protected]