CIRCULAR OF THE STATE ADMINISTRATION OF TAXATION ON THE EFFECTIVENESS OF THE EXCHANGE OF LETTERS FOR MUTUAL EXEMPTION OF TAX ON INTERNATIONAL AIR TRANSPORT INCOME BETWEEN CHINA AND LUXEMBOURG

The State Administration of Taxation

Circular of the State Administration of Taxation on the Effectiveness of the Exchange of Letters for Mutual Exemption of Tax on International
Air Transport Income between China and Luxembourg

Guo Shui Fa [2005] No.143

The bureaus of state taxation and the bureaus of local taxation of all the provinces, autonomous regions, municipalities directly
under the Central Government, and cities specifically designated in the state plan, Yangzhou Taxation Institute, and all the entities
directly under the State Administration of Taxation,

The Exchange of Letters between the Government of the People’s Republic of China and the Government of the Grand Duchy of Luxembourg
for Mutual Exemption of Tax on International Air Transport Income of Air Transport Enterprises was signed by Xie Xuren, Director
General of the State Administration of Taxation and Juncker, Finance Minister of Luxembourg on July 22nd, 2005 and August 4th, 2005
respectively on behalf of their own government, and is hereby printed and distributed to you. The Exchange of Letters shall go into
effect since August 4, 2005, and shall be implemented since October 1st, 2005.

Annex: Exchange of Letters between the Government of the People’s Republic of China and the Government of the Grand Duchy of Luxembourg
for Mutual Exemption of Tax on International Air Transport Income of Air Transport Enterprises

State Administration of Taxation

September 12, 2005 Annex:Exchange of Letters between the Government of the People’s Republic of China and the Government of the Grand Duchy of Luxembourg for
Mutual Exemption of Tax on International Air Transport Income of Air Transport Enterprises

Letter of the Chinese Party

Your Excellency,

It’s my honor to refer to the issue of exemption of tax on income obtained from undertaking international transport by the air enterprises
of both countries, and suggest making the following arrangements on behalf of the government of the People’s Republic of China:

All the taxes shall be exempted in the opposite country on the income, profit and proceeds obtained from undertaking international
transport business in the opposite country by the air transport enterprises designated by the governments of both countries.

If Your Excellency accepts the said arrangements, it’s my honor to suggest that this letter and the letter of reply acknowledged by
Your Excellency on the government of the Grand Duchy of Luxembourg’s acceptance of the aforesaid suggestions proposed by the government
of the People’s Republic of China shall constitute an agreement between the governments of both countries. The said agreement shall
enter into force as of the date when Your Excellency makes a letter of reply.

With highest respect.

Representative of the Government of the People’s Republic of China

Director General of the State Administration of Taxation: Xie Xuren

July 22nd, 2005

Letter of the Luxembourg Party

Your Excellency,

It’s my honor to acknowledge the receipt of your letter, dated July 22nd, 2005, which reads as follows,

“It’s my honor to refer to the issue of exemption of tax on income obtained from undertaking international transport by the air enterprises
of both countries, and suggest making the following arrangements on behalf of the government of the People’s Republic of China:

All the taxes shall be exempted in the opposite country on the income, profit and proceeds obtained from undertaking international
transport business in the opposite country by the air transport enterprises designated by the governments of both countries.

If Your Excellency accepts the said arrangements, it’s my honor to suggest that this letter and the letter of reply acknowledged by
Your Excellency on the government of the Grand Duchy of Luxembourg’s acceptance of the aforesaid suggestions proposed by the government
of the People’s Republic of China shall constitute an agreement between the governments of both countries. The said agreement shall
enter into force as of the date when Your Excellency makes a letter of reply.

With highest respect.

Representative of the Government of the People’s Republic of China

Director General of the State Administration of Taxation: Xie Xuren”

I sincerely acknowledge that the Luxembourg agrees with the contents of the letter, and avail myself of this opportunity to renew
to Your Excellency the assurances of my highest respect.

Representative of the Government of the Grand Duchy of Luxembourg

Finance Minister Jean-Claude Juncker