Treaty detail
United Kingdom - China tax treaty
A practical treaty page built around the official treaty text, key withholding categories, permanent-establishment rules, and article-level summaries.
Signed
2011-06-27
Effective
2013-12-13
Articles seeded
6
Withholding snapshot
Dividends
Individual rate: 10% · Corporate rate: 5%
The lower 5 percent corporate rate generally depends on a direct-ownership threshold under the treaty. China's domestic dividend-withholding rules continue to apply where treaty conditions are not satisfied.
Interest
Rate: 10%
The treaty applies a 10 percent ceiling on most interest. Certain government, central-bank, and qualifying-institution interest may obtain better treatment under the article.
Royalties
Rate: 10%
Royalties generally face a 10 percent ceiling, with a 6 percent reduced rate for certain industrial-equipment categories under the article.
Permanent establishment
Construction threshold: more than 12 months
Dependent-agent analysis follows the OECD model wording as adapted in the 2011 treaty.
Other treaty flags
Pension treatment is article-specific. The treaty includes detailed pension and government-service articles.
Seeded article summaries
Article 4
Residence
Defines treaty residence under modern OECD-aligned rules.
Article 4 reflects the 2011 modernization. Residence analysis interacts with China's developing rules on Place-of-Effective-Management for foreign-incorporated entities.
Article 5
Permanent Establishment
Sets the business-presence threshold including service-PE provisions.
The treaty includes both a construction-site threshold and a service-PE rule. The service-PE provision can create a permanent establishment based on the furnishing of services beyond a defined number of days.
Article 7
Business Profits
Generally reserves business profits to the residence state in the absence of a PE.
Article 7 is the operating rule for cross-border services. The interplay with the service-PE rule in Article 5 makes day-counting important for many service arrangements.
Article 10
Dividends
Caps source-country withholding on dividends at treaty ceilings that vary with shareholding.
Article 10 produces the 10 percent and 5 percent treaty ceilings. China's domestic dividend rules continue to apply where treaty conditions are not satisfied.
Article 11
Interest
Limits source-country withholding on qualifying interest to a 10 percent ceiling.
Article 11 produces a 10 percent ceiling on most interest, with carve-outs for government and central-bank interest under the article.
Article 12
Royalties
Limits source-country royalty withholding to treaty ceilings that vary with category.
Article 12 caps royalties at 10 percent generally, with a 6 percent reduced rate for certain industrial-equipment categories under the article. Category classification matters significantly.
Official text
Other treaties involving these jurisdictions
Computed from the cross-reference graph. Links open the related entity on this site.
This entry cites
- TreatyUS–GB treaty
- TreatyUS–CN treaty
- TreatyGB–CA treaty
- TreatyGB–AU treaty
- TreatyGB–DE treaty
- TreatyGB–FR treaty
- TreatyGB–JP treaty
- TreatyGB–IE treaty
Primary sources
- HMRC: China tax treatyVerified 2026-05-20
- State Taxation Administration of ChinaVerified 2026-05-20
- OECD MLI matching databaseVerified 2026-05-20
Important disclaimer
This library is for general tax education only. Always verify filing obligations, due dates, and tax consequences against the cited primary source or with a qualified tax professional.