中赞税收协定-英文.pdfVIP

AGREEMENT BETWEEN THE GOVERNMENT OF THE PEOPLES REPUBLIC OF CHINA AND THE GOVERNMENT OF THE REPUBLIC OF ZAMBIA FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME The Government of the Peoples Republic of China and the Government of the Republic of Zambia, Desiring to conclude an Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income (hereinafter referred to as the Agreement), Have agreed as follows: Article 1 PERSONS COVERED This Agreement shall apply to persons who are residents of one or both of the Contracting States. Article 2 TAXES COVERED 1. This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or its local authorities, irrespective of the manner in which they are levied. 2. There shall be regarded as taxes on income all taxes imposed on total income, or on elements of income, including taxes on gains from the alienation of movable or immovable property, taxes on the total amounts of wages or salaries paid by enterprises, as well as taxes on capital appreciation. 3. The existing taxes to which the Agreement shall apply are in particular : a) in China: (i) the individual income tax; (ii) the enterprise income tax. (hereinafter referred to as Chinese tax) b) in Zambia: the income tax. (hereinafter referred to as Zambian tax) 1 4. The Agreement shall apply also to any identical or substantially similar taxes that are imposed after the date of s