Double taxation agreement between China and Austria

The double taxation agreement between China and Austria was recently amended. The most important changes are:

  • Reduction of the withholding tax rate for dividends to certain beneficiary shareholders (>25% participation or directly or indirectly participating government entities) to 5%.
  • Introduction of exemptions for withholding taxes on interest payments made to government entities or for interest related to the sale of equipment, goods, or services on credit.
  • Adjustments regarding the determination of the source state of license fees.
  • The permanent establishment period for construction work has been extended from six to twelve months and also includes supervisory activities related to construction work
  • At the same time, it was clarified that services in connection with construction work do not qualify as a service permanent establishment

The withholding tax rate for dividends, interest, and license fees remains unchanged at 10%.



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