China

's Notice 82.

The People's Republic of China adopted a law, called Notice 82, which will change the position of offshore private equity firms who control enterprises in China. No.82 prescribes that non-Chinese firms will be considered PRC tax residents when their effective management is located in the PRC. The criteria the PRC imposes on these overseas incorporated domestically-controlled enterprises (OIDCE), also referred to as 'red chips', demand that the big private equity firms and international holdings who do not manage the day-to-day activities of their Chinese firms, do not collect payments of interest or dividends.

http://www.kpmg.com.cn/en/virtual_library/Tax/tax_alert/Taxalert0910.pdf