Agreement between the Government of the Hong Kong Special Administrative Region of the People's Republic of China and the Government of the Democratic Socialist Republic of Sri Lanka for the Avoidance of Double Taxation with Respect to Taxes on Income Derived from Shipping and Air Transport
Taxes Covered
The existing taxes to which this Agreement shall apply are:
In the case of the Hong Kong Special Administrative Region:
- Profits tax and
- Salaries tax (hereinafter referred to as "Hong Kong Special Administrative Region tax");
In the case of the Democratic Socialist Republic of Sri Lanka:
- The income tax (hereinafter referred to as "Sri Lanka tax").
Avoidance of Double Taxation
- Profits of an enterprise of a Contracting Party derived from the operation of aircraft in international traffic shall be taxable only in the area of that Contracting Party.
- Profits of an enterprise of a Contracting Party derived in the area of the other Contracting Party from the operation of ships in international traffic may be taxed in the area of the other Contracting Party but the tax so charged shall be reduced by an amount equal to fifty per centum thereof.
- Remuneration derived in respect of an employment exercised aboard a ship or aircraft operated in international traffic by an enterprise of a Contracting Party shall be taxable only in the area of that Contracting Party.
Mutual Agreement Procedure
The competent authorities of the Contracting Parties shall endeavor to resolve by consultation any difficulties or doubts arising as to the interpretation or application of this Agreement. They may also consult together for the avoidance of double taxation in cases not provided for in this Agreement.
Entry into Force
Each Contracting Party shall notify the other Contracting Party of the completion of the procedures required by its law for the bringing into force of this Agreement. This Agreement shall enter into force on the date of the later of these.
Termination
This Agreement shall remain in force indefinitely but either Contracting Party may terminate this Agreement by:
- Giving written notice of termination to the other Contracting Party at least six months before the end of any calendar year after the fifth year following that in which it enters into force. In such event, this Agreement shall cease to have effect for any year of assessment beginning on or after 1 April in the calendar year next following that in which notice is given.
Last Updated on: 19-05-2010
