Circular of the State Administration of Taxation on the Issues concerning the Interpretation and Implementation of Clauses of the Agreement between China and Singapore on the Avoidance of Double Taxation

Circular of the State Administration of Taxation on the Issues concerning the Interpretation and Implementation of Clauses of the Agreement between China and Singapore on the Avoidance of Double Taxation

Guo Shui Han [2007] No.1212

December 6, 2007

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

The Agreement between the Government of the People's Republic of China and the Government of the Republic of Singapore on the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income (hereinafter referred to as the "Agreement") was duly concluded on July 11, 2007 and came into force as of September 18, 2007, and applies to the income earned as of January 1, 2008. The Agreement is a comprehensive amendment to the original agreement between the governments of China and Singapore on the avoidance of double taxation; therefore, the original agreement and the protocol shall cease to be effective as of the date when the Agreement comes into force. For the purpose of doing well the implementation of the Agreement, the issues concerning the interpretation of clauses of the Agreement are hereby defined as follows:

I. Implementation Time of the Agreement
1. The Agreement shall come into force as of January 1, 2008 and applies to the income earned by the taxpayers as of January 1, 2008.
2. The rateability of resident individuals shall be calculated as of January 1, 2008 to implement the provisions of the Agreement; the calculation of the rateability of the engineering projects or activities commencing earlier than January 1, 2008 of resident enterprises shall be continued rather than interrupted to implement the provisions of the Agreement, as the criteria of the new agreement for the timing are as same as those of original agreement.

II.
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