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These notes are issued for the information of taxpayers and their tax - page 2 / 68

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2 / 68

DEPARTMENTAL INTERPRETATION AND PRACTICE NOTES

No. 44(REVISED)

CONTENT

Paragraph

Introduction

1

Arrangement for the avoidance of double taxation

3

Relationship between the comprehensive arrangement and the Ordinance

5

Effective dates and applicable text

8

Article 1

Persons covered

11

Article 2

Taxes covered

Article 3

General definitions

12

15

Article 4

Resident

(I) Resident

individual

(II) Resident

company

(III) Resident

persons other

than

individuals

and

19 21 26 31

companies Certification of resident status

32

Article 5

Permanent establishment The concept of a permanent establishment A building site, a construction, assembly or

36 38

installation project Provision of services by an enterprise

42

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