State Administration of Taxation, Circular on Issues Relevant to the Interpretation and Implementation of Relevant Articles of the «Arrangement Between the Mainland of China and the Hong Kong Special Administrative Region for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income»
关于《内地和香港特别行政区关于对所得避免双重征税和防止偷漏税的安排》有关条文解释和执行问题的通知
May 02, 2007 | BY
clpstaff &clp articles &Avoidance of double taxation issues between Hong Kong and the mainland clarified.
Issued: April 4 2007
Main Contents: The Circular clarifies relevant articles of the Arrangement Between the Mainland of China and the Hong Kong Special Administrative Region for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (the Arrangement) concerning issues such as:
(1) relationship between the Arrangement and tax regulations;
(2) date of implementation of the Arrangement;
(3) definition and determination of resident;
(4) definition of permanent establishment; and
(5) levying of taxes on interest income, capital gains, income from employment and income from provision of services by independent individuals.
Related Legislation: Arrangement Between the Mainland of China and the Hong Kong Special Administrative Region for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income, Aug 21 2006
Full Analysis & Translation: See page 70
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