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These notes are issued for the information of taxpayers and their tax - page 6 / 68

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Income”(“the Second Protocol”) on 11 September 2007 and 30 January 2008 respectively.

ARRANGEMENT FOR THE AVOIDANCE OF DOUBLE TAXATION

3.

For the purpose of giving effect to the Comprehensive Arrangement,

an Order (“Specification of Arrangements (the Mainland of China) (Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income) Order”) was made by the Chief Executive in Council on 27 October 2006, under section 49 of the Inland Revenue Ordinance (Cap. 112) (“the Ordinance”). The Order was published in the Gazette as Legal Notice 234 of 2006. For the purpose of giving effect to the Second Protocol, an Order (“Specification of Arrangements (the Mainland of China) (Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income) (Second Protocol) Order”) was made by the Chief Executive in

Council on 15 April 2008. Notice 89 of 2008.

The Order was published in the Gazette as Legal

4.

The purpose of the Comprehensive Arrangement is to allocate the

right to tax between the two Sides on a reasonable basis so as to avoid double taxation of the same item of income in both Sides. The provisions of the Comprehensive Arrangement have been made by reference to those contained

in the Model Tax Conventions of the Organisation for and Development (the “OECD”) and the United

Economic Nations.

Co-operation Appropriate

modifications have been made to cope with the particular requirements of

Mainland and Hong Kong.

In

provisions

of

the

Comprehensive

the interpretation and application of Arrangement, both Sides will refer to

the the the

Vienna Convention relevant Articles of Nations, as well as

on the Law of Treaties (1969), the Commentaries on the the Model Tax Conventions of the OECD and the United to their respective principles of interpretation of taxation

law.

2

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