The article investigates the peculiarities of definition and application of the beneficial owner concept in Chinese tax law. The author reveals the complex process of determining beneficial owner, which includes various types of tests and requires analysis of many factors. In reviewing the practice of the Chinese tax authorities, the author also demonstrates the low legal certainty of this concept and the potential risks for cross-border investors, which not only helps to improve the concept of the Chinese tax system, but can also serve as a reference for tax advisors.