No More Tax Exemption on Interest and Dividend to
Expats in China
The exemption previously enjoyed by
overseas nationals on gains from foreign-funded firms in China was cancelled in
an announcement on Tuesday
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China has ended the individual income-tax exemption
on dividends and bonuses earned by expatriates from foreign-invested
enterprises.
·
A 20% tax rate on “interest, dividend and bonus
income” takes effect immediately, according to the Ministry of Finance and
State Taxation Administration.
·
The exemption had existed since 1994 to support
reform, opening-up and foreign investment.
·
Authorities say the change unifies the tax system
and removes unequal treatment: foreign investors had tax-free dividends while
Chinese investors paid tax.
·
It also closes an arbitrage route in which domestic
firms could restructure as foreign-invested enterprises to distribute
tax-exempt dividends.
·
Foreign-funded firms must withhold and remit the
tax when dividends or bonuses are paid, then file returns within 15 days after
the following month.
·
If the company does not withhold the tax, the
foreign recipient must pay it by 30 June of the next year, or sooner if
authorities set a deadline.
·
It remains unclear whether the rule applies to
individuals from Hong Kong, Macau and Taiwan, or to foreigners living overseas.
·
China says foreign recipients may be able to claim
tax credits in their country of tax residence, potentially limiting any
increase in their overall tax burden.
·
The move forms part of broader efforts to tighten
oversight of cross-border financial flows, curb tax avoidance and reduce
capital flight.
China’s
tax authorities announced on Tuesday (01.09.2026) that the country would end
the tax exemption for dividends earned by expatriates at foreign-funded firms,
setting a 20 per cent rate effective immediately.
The
measures mainly target “interest, dividend and bonus income” for individual
income tax purposes, according to a joint statement from the Ministry of
Finance and State Taxation Administration.
State
news agency Xinhua said the change was needed for the “unification of the tax
system”.
In
1994, China put in place a tax exemption on dividend and bonus income that
foreign individuals earned from foreign‑invested enterprises. At the
time, the measure was designed to advance reform and opening‑up and draw
foreign investment.
A
tax‑service hotline representative said that because the guideline was
newly issued, immediate confirmation was not available on whether the new rule
would cover individuals in Hong Kong, Macau and Taiwan, or foreigners living
overseas.
“This
change upholds fairness in the tax system. Previously, foreign investors
received tax‑exempt dividends while Chinese investors paid tax. Such
differential treatment runs counter to the principle of tax neutrality,” said
Fu Yifu, a special research fellow at Su Merchants Bank in Nanjing, in China’s
eastern Jiangsu province.
“Foreign
investors in China value comprehensive strengths such as its rule‑of‑law
environment, market size and industrial support, not merely a handful of tax
incentives. Phasing out these remaining differential treatment policies will
foster a more efficient, well‑regulated unified market system,” Fu said.
The
latest measure comes amid a raft of initiatives that Beijing has rolled out in
recent months to tighten oversight of cross-border financial flows, aimed at
curbing tax avoidance and capital flight.
China
announced new rules in July, bringing income generated through offshore trusts
under its personal income tax regime, closing a loophole that had enabled
wealthy Chinese households to shield large sums of income from taxation.
With
a unified national market taking shape, China is progressively regulating
preferential tax policies.
“In
past practice, some domestic firms rebranded as foreign‑invested
enterprises to siphon profits via large dividends and access tax-exempt
benefits, causing tax revenue losses. The new rule has fully closed such
arbitrage opportunities,” Fu said.
In
addition, if their tax residence country allowed tax credits, taxes that
foreign individuals pay in China could offset their local tax liabilities.
Their overall tax burden therefore might not rise materially, Fu added.
According
to the new guideline, foreign‑funded enterprises would need to withhold
and remit tax when paying dividends and bonuses to foreigners, and the foreign
firms would file tax returns within 15 days of the month after payment, the
statement said.
If
the enterprise failed to withhold taxes, the foreign individual receiving
dividends would be required to pay the tax on or before 30 June of the
following year. If tax authorities issued a time-limited payment notice, the
foreign individual would be required to comply with that deadline, it added.