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These notes are issued for the information of taxpayers and their tax - page 64 / 68

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competent authority of the Other Side, with a view to the avoidance of taxation

which is not in accordance with the agreement reached shall be implemented respective domestic laws of both Sides.

Comprehensive notwithstanding

Arrangement. any time limits

Any in the

147.

Hong Kong residents presenting to the Commissioner of Inland

Revenue a case which satisfies the requirements set out in paragraph 145 above, should also provide all information relevant to the case (e.g. details of activities that give rise to taxation carried out in the Mainland or in Hong Kong, details of negotiations with the competent authority of the Mainland including copies of documents, letters, notices of assessment and demand notes), so that the Inland Revenue Department may examine the case and consult with the

competent authority of the Mainland.

Article 24

EXCHANGE OF INFORMATION

148.

In

line

with

international

practice,

the

Comprehensive

Arrangement

contains provisions on the exchange of information. Paragraph 1 of Article 24 states that the competent authorities of both Sides shall exchange such information as is necessary for carrying out the provisions of the Comprehensive Arrangement or of the domestic laws of both Sides concerning taxes covered by the Comprehensive Arrangement. Paragraph 1 also makes it clear that the exchange of information is not restricted by Article 1 (Persons Covered), i.e. information relating to persons who are not residents of One Side

or both Sides may be exchanged, provided for purposes compatible with this Article.

that

the

exchange

of

information

is

149.

In order to ensure that information relating to taxpayers will not be

misused, the Comprehensive Arrangement provides that any information received by One Side from the Other Side shall be treated as secret in the same manner as information obtained under the domestic laws of that Side. In other words, both the Mainland and Hong Kong shall keep information obtained from the other party confidential and such information shall be disclosed only to persons or authorities concerned with the assessment or collection of, the enforcement or prosecution in respect of, or the determination of appeals in

relation to, the taxes covered by the Comprehensive Arrangement. persons or authorities shall use the information only for such purposes.

Such They

60

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