China-Singapore中国新加坡避免双重征税协定.pdf

AGREEMENT BETWEEN THE GOVERNMENT OF THE PEOPLE S REPUBLIC OF CHINA AND THE GOVERNMENT OF THE REPUBLIC OF SINGAPORE FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME The Government of the People s Republic of China and the Government of the Republic of Singapore, DESIRING to conclude an Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income, HAVE AGREED as follows: 1 Article 1 Persons Covered This Agreement shall apply to persons who are residents of one or both of the Contracting States. 2 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. 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 Singapore: the Income Tax (hereinafter referred to as Singapore tax).