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AGREEMENTBETWEEN THE GOVERNMENT OF THE PEOPLE’S REPUBLIC OF CHINA AND THE GOVERNMENT OF THE REPUBLIC OF CONGO FOR THE ELIMINATION OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF TAX EVASION AND AVOIDANCE

中华人民共和国政府和刚果共和国政府对所得消除双重征税和防止逃避税的协定

[CLI Code] CLI.T.9002(EN)  Statement

  • AGREEMENT BETWEEN THE GOVERNMENT OF THE PEOPLE'S REPUBLIC OF CHINA AND THE GOVERNMENT OF THE REPUBLIC OF CONGO FOR THE ELIMINATION OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF TAX EVASION AND AVOIDANCE

  • 中华人民共和国政府和刚果共和国政府对所得消除双重征税和防止逃避税的协定

  • The Government of the People's Republic of China and the Government of The Republic of Congo, Desiring to further develop their economic relationship and to enhance their cooperation in tax matters, Intending to conclude an Agreement for the elimination of 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 reliefs provided in this Agreement for the indirect benefit of residents of third States), Have agreed as follows:
  • 中华人民共和国政府和刚果共和国政府,为了进一步发展两国经济关系,加强税收事务合作,愿意缔结一项协定,以消除对所得的双重征税,同时防止逃避税行为造成的不征税或少征税(包括第三国居民通过择协避税安排,取得本协定规定的税收优惠而间接获益的情况),达成协议如下:
  • ARTICLE 1 PERSONS COVERED
  •   第一条 人的范围
  • 1. This Agreement shall apply to persons who are residents of one or both of the Contracting States.
  • 一、本协定适用于缔约国一方或者同时为双方居民的人。
  • 2. For the purposes of this Agreement, income derived by or through an entity or arrangement that is treated as wholly or partly fiscally transparent under the tax law of either Contracting State shall be considered to be income of a resident of a Contracting State but only to the extent that the income is treated, for purposes of taxation by that State, as the income of a resident of that State.
  • 二、在本协定中,按照缔约国任何一方的税法视为完全透明或部分透明的实体或安排,其取得或通过其取得的所得应视为缔约国一方居民取得的所得,但仅以该缔约国一方在税收上将该所得作为其居民取得的所得处理为限。
  • 3. This Agreement shall not affect the taxation, by a Contracting State, of its residents except with respect to the benefits granted under paragraph 2 of Article 9 and Articles 19, 20, 22, 23, 24 and 27.
  • 三、除第九条第二款、第十九条、第二十条、第二十二条、第二十三条、第二十四条及第二十七条所规定的税收待遇外,本协定不应影响缔约国一方对其居民的征税。
  • ARTICLE 2 TAXES COVERED
  •   第二条 税种范围
  • 1. This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.
  • 一、本协定适用于缔约国一方或其行政区或地方当局对所得征收的税收,不论其征收方式如何。
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