EXCHANGE OF NOTES TO THE AGREEMENT BETWEEN THE GOVERNMENT OF THE PEOPLE's REPUBLIC OF CHINA AND THE GOVERNMENT OF THE REPUBLIC OF SINGAPORE FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF F
颁布时间:1986-04-18
HE Mr. Xiang Huaicheng
Vice Commissioner
of the State Administration of Taxation
of the People's Republic of China
Excelleny,
I have the honour to acknowledge receipt of Your Excellency's Note of
today's date, which reads as follows:
"I have the honour to refer to the Agreement between the Government of
the People's Republic of China and the Government of the Republic of
Singapore for the Avoidance of Double Taxation and the Prevention of
Fiscal Evasion with respect to Taxes on Income signed at Singapore on 18
April 1986 (hereinafter referred to as "the Agreement") and to propose on
behalf of the Government of the People's Republic of China the following
arrangement:
1. Sub-paragraph (a) of paragraph 3 of Article 2 of the Agreement
shall be deleted and replaced by the following:
(a) in the People's Republic of China:
(i) the individual income tax;
(ii) the income tax for enterprises with foreign investment and
foreign enterprises; and
(iii) the local income tax.
(hereinafter referred to as "Chinese Tax")
2. Sub-paragraphs (a) and (b) of paragraph 4 of Article 24 of the
Agreement shall be deleted and replaced by the following:
(a) the provisions of Articles 7, 8, 9 and 10 of the Income Tax Law of
the People's Republic of China for Enterprises with Foreign Investment and
Foreign Enterprises and the provisions of Article 73, 75 and 81 of the
Detailed Rules and Regulations for the Implementation of the Income Tax
Law of the People's Republic of China for Enterprises with Foreign
Investment and Foreign Enterprises.
3. Sub-paragraphs (c) and (d) of paragraph 4 of Article 24 of the
Agreement shall be read as (b) and (c) respectively.
I have the honour to propose that this Note and Your Excellency's Note
in reply confirming the acceptance by the Government of the Republic of
Singapore of the above proposal shall be regarded as constituting an
agreement between the two Governments under paragraph 4 of Article 2 and
sub-paragraph (d) of paragraph 4 of Article 24 of the Agreement, which
will enter into force on the date of Your Excellency's reply and shall
have effect in respect of income derived on or after July first, 1991.
Done in the Chinese and English languages, both texts being equally
authentic.
I avail myself of this opportunity to extend to Your Excellency the
assurances of my highest consideration."
I have further the honour to confirm the acceptance by the Government
of the Republic of Singapore of the above proposal and agree that Your
Excellency's Note and this Note shall be regarded as constituting an
agreement between the two Governments which will enter into force on the
date of this reply.
Done in the English and Chinese languages, both texts being equally
authentic.
I avail myself of this opportunity to extend to Your Excellency the
assurances of my highest consideration.
Cheng Tong Fatt
Ambassador Extraordinary and Plenipotentiary of the Republic of
Singapore to the People's Republic of China