CIRCULAR OF THE STATE ADMINISTRATION OF TAXATION ON THE RELEVANT ISSUES CONCERNING THE IMPLEMENTATION OF THE INTEREST CLAUSES IN SINO-CANADA AGREEMENT ON TAXATION
Circular of the State Administration of Taxation on the Relevant Issues Concerning the Implementation of the Interest Clauses in Sino-Canada Guo Shui Fa [2006] No. 126 The state taxation bureaus and local taxation bureaus of all provinces, autonomous regions, municipalities directly under the Central Upon the request of the taxation authorities of Canada, the representatives of the taxation authorities of China and Canada have negotiated I. Paragraph 3 of Article 11 of the Chinese version shall be amended to be: “Notwithstanding the provisions of Paragraph 2, the interests occurred in one of the contracting states shall be exempted from taxation i. In respect of Canada: 1. Paid to the Canadian Government; 2. Paid to the Bank of Canada; 3. Paid due to the direct or indirect loans or loans guaranty by Export Development Canada; 4. Paid to the financial institutions owned by the Canadian Government and recognized by both of the competent authorities of the contracting ii. In respect of the People’s Republic of China: 1. Paid to the government of the People’s Republic of China; 2. Paid to the People’s Bank of China; 3. Paid due to the direct or indirect loans or loans guaranty by the Bank of China or China International Trust and Investment Corporation 4. Paid to the financial institutions owned by the government of the People’s Republic of China and recognized by both of the competent II. The English name of “Canadian Export Development Corporation” in the text of the Agreement shall be changed to be “Export Development Please carry out the present notice accordingly. The State Administration of Taxation August 18, 2006 |
The State Administration of Taxation
2006-08-18