The State Administration of Taxation has issued the Announcement on the Clarification of the Tax Arrangement Clauses by the Tax Authorities of the Mainland and Macao (the "Announcement").
Paragraph 3, Article 11 of the Arrangement between Mainland China and the Macao Special Administrative Region for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (the "Arrangement") provides, in general, the financial institutions that are exempted from tax on income from interest but fails to specify these institutions. The Announcement clarifies that the institutions approved by the competent authorities of the two sides mentioned in Paragraph 3, Article 11 of the Arrangement refer to, in the Macao Special Administrative Region, the Monetary Authority of Macao, Pension Fund and Social Security Fund; and in the Mainland, China Development Bank, Export-Import Bank of China, Agricultural Development Bank of China, National Council for Social Security Fund and China Export and Credit Insurance Corporation.