Circular of the State Administration of Taxation concerning the Effectiveness and Implementation of the Memorandum of Understanding on the Agreement between the Government of the People's Republic of China and the Government of the Republic of Korea for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to Taxes on Income
Guo Shui Fa [2007] No.86
Memorandum of Understanding on the Agreement between the Government of the People's Republic of China and the Government of the Republic of Korea for the Avoidance of Double Taxation and Prevention of Fiscal Evasion with respect to Taxes on Income
(1) in the case of the People's Republic of China:
(a) People's Bank of China;
(b) China Development Bank;
(c) The Export-import Bank of China;
(d) Agriculture Development Bank of China;
(e) China Export & Credit Insurance Corporation;
(f) National Council for Social Security Fund;
(g) Organizations which have the ownership structure and function and are equivalent to "Investment Company of the Republic of Korea" (The name is to be set by authorities of both parties via exchange of letter);
(h) Organizations which perform the functions of banking, insurance and securities; and
(i) Other financial institutions agreed by both contractual states through negotiation.
(2) in the case of Republic of Korea:
(a) Bank of Korea;
(b) Korea Development Bank;
(c) Korea Export-import Bank;(
d) Korea Investment Corporation;(
e) Korea Export Insurance Corporation;
(f) Financial Supervisory Service;
(g) Other financial institutions agreed by the competent authorities of the Contracting States through mutual agreement.
2. The provisions of paragraphs 1 and 2 of Article 19 shall also apply to the remuneration or pensions paid by the following institutions:(
1) in the case of China:
(a) People's Bank of China;
(b) China Development Bank;
(c) Export-import Bank of China;
(d) Agricultural Development Bank of China;
(e) China Council for the Promotion of International Trade;
(f) China Export & Credit Insurance Corporation;
(g) National Council for Social Security Fund;
(h) Organizations which have the ownership structure and function and are equivalent to "Investment Company of the Republic of Korea" (the name is to be set by authorities of both parties via exchange of letter);
(i) Organizations with executive banking, insurance and securities supervisory functions; and
(j) Other financial institutions agreed by both contractual states through negotiation.
(2) in the case of Korea:
(a) Bank of Korea;
(b) Korea Development Bank;
(c) Korea Export-import Bank;(
d) Korea Trade-Investment Promotion Agency;
(e) Korea National Tourism Corporation;
(f) Korea Investment Corporation;
(g) Korea Export Insurance Corporation;
(h) Financial Supervisory Service;
(i) Other financial institutions agreed by both contractual states through negotiation.
3. The Memorandum shall come into force as of the date of its official signature, and shall supersede the Memorandum of Understanding on the Tax Agreement between the Government of the People's Republic of China and the Republic of Korea signed on November 26, 1994.
