African countries benefiting from double taxation rules include Algeria, Botswana (signed but not yet effective), Egypt, Ethiopia, Mauritius, Morocco, Nigeria, Seychelles, South Africa, Sudan, Uganda (signed but not yet effective), Zambia and Zimbabwe. China signed an OECD multilateral instrument in 2017. This Directive updates most of the double taxation conventions previously signed and contains many minor amendments. A striking update is the introduction of an anti-abuse test that will subsequently reduce the chances of double taxation being exploited. It is therefore essential for all companies benefiting from double taxation relief in accordance with the principles of the Treaty to review new updates and identify changes (if any) to their current tax systems. Now let`s take a look at the rules of the double taxation convention for different types of taxes. Beyond the above points, the new updated contracts contain different BEPS provisions, including PPTs; the new preamble to the BEPS Treaty; the residency tie-breaker on the basis of mutual agreement; and the exchange of information and modernized MAP items. These are in line with changes to China`s MLI treaties. The latter will update and increase 63 Chinese tax agreements, with the accession of other Chinese parties to the MFI. However, it is not yet known when China will have completed the national procedures for ratifying the MFI.

Double taxation treaties with countries in Asia and Oceania include Australia, Azerbaijan, Bahrain, Bangladesh, Brunei, Cambodia (signed but not yet effective), Georgia, India, Indonesia, Iran, Israel, Japan, Kazakhstan, Kuwait, Kyrgyzstan, Laos, Malaysia, Mongolia, Nepal, New Zealand, Oman, Pakistan, Papua New Guinea, Philippines, Qatar, Saudi Arabia, Singapore, Sri Lanka, Syria, Tajikistan, Thailand, Tunisia, Turkmenistan, Turkey, The United Arab Emirates and Vietnam. One of the main features of new contracts/updates is that most of them contain provisions relating to transparent units. This is the case for the agreements concluded with India, New Zealand, Italy, Spain, Argentina and the Congo. These provide that, to the extent that the country of establishment of the unit concerned (e.g. .B the partnership) allows transparent treatment (the income from the partnership is reserved for the underlying partners) that adopts the same treatment in the country of origin, including China. . . .