China Law Online Database : novexcn.com

You are using Guest Account

Subscribe To This Law Only

Subscribe To All Law Contents

Print This Page

Back




	REPLY OF STATE ADMINISTRATION OF TAXATION REGARDING CORPORATE INCOME TAX EXEMPTION FOR LOAN INTERESTS INCOME OBTAINED BY JAPAN BANK FOR INTERNATIONAL COOPERATION

	(No.830 [2003] of State Administration of Taxation, July 10, 2003)


SUBJECT : CORPORATE TAX; INTEREST INCOME; EXEMPTION; JAPAN
ISSUING DEPARTMENT : STATE ADMINISTRATION OF TAXATION
ISSUE DATE : 07/10/2003
IMPLEMENT DATE : 07/10/2003
LENGTH : 295 words
TEXT :

Regarding Request for Instructions on Exemption of Withholding Income Tax for Loan Interests Obtained from Dongli Jiuyi Weaving & Dyeing Co., Ltd. (Nantong) by Japan Bank for International Cooperation (No.115 [2003] of Administration of State Taxes of Jiangsu Province) and the Request for Instructions on Exemption of Withholding Income Tax for Loan Interests Obtained from Nantong Liyang Chemicals Co., Ltd. by Japan Bank for International Cooperation (No.118 [2003] of Administration of State Taxes of Jiangsu Province), we reply as follows upon deliberation:

Dongli Jiuyi Weaving & Dyeing Co., Ltd. (Nantong) concluded a loan agreement with Japan Bank for International Cooperation in September 1997, with the loan amount at US$8,000,000; and Nantong Liyang Chemicals Co., Ltd. concluded a loan agreement with Japan Bank for International Cooperation, with the loan amount at US$6,500,000. According to Article 1 of the Circular of State Administration of Taxation on Relevant Issues Concerning the Implementation of the Tax Agreement on Income Tax Exemption for Interest (No.29 [1996] of State Administration of Taxation), which provides that Japan Bank for International Cooperation shall be the financial institution wholly owned by the Japanese Government, and Section 3 of Article 11 of the Agreement Between the Government of the People's Republic of China and the Government of Japan for the Avoidance of Double Taxation and the Prevention of Tax Evasion, which provides that interest arising in a contracting state and derived by the government of the other contracting state, a political subdivision or local authority, the central bank of that other contracting state or any financial institution wholly owned by that government shall be exempt from tax in the contracting state, we agree to the enterprise income tax exemption for the interest of the above two loans obtained by Japan Bank for International Cooperation.