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The Fifth Protocol to the Arrangement between the Mainland of China and the Hong Kong Special Administrative Region for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

《内地和香港特别行政区关于对所得避免双重征税和防止偷漏税的安排》第五议定书

[CLI Code] CLI.T.9148(EN)  Statement

  • The Fifth Protocol to the Arrangement between the Mainland of China and the Hong Kong Special Administrative Region for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income
  • 《内地和香港特别行政区关于对所得避免双重征税和防止偷漏税的安排》第五议定书

  • Article 1
  • 第一条
  • “The Mainland of China and the Hong Kong Special Administrative Region, desiring to further develop their economic relationship and to enhance their co-operation in tax matters, intending to eliminate double taxation with respect to taxes on income without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining tax reliefs provided in this Arrangement for the indirect benefit of residents of third tax jurisdictions), have agreed as follows:”
  • “内地和香港特别行政区,为进一步发展双方的经济关系,加强双方税收事务合作,亦为消除对所得的双重征税,并防止通过逃避税行为造成不征税或少征税(包括通过择协避税筹划取得本安排规定的税收优惠而使第三方税收管辖区居民间接获益的情况),达成协议如下:”
  • Article 2
  • 第二条
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