ˇˇWe now forward to you the Notice of the State Administration of Taxation on the Letter Exchange between the Chinese and Italian Government Concerning Tax Clauses in the Marine Agreement Becoming Effective (G. S. F. [2005] No. 53). Please implement it.
May 30, 2005
Document of the State Administration of Taxation
G. S. F. [2005] No. 53
Notice of the State Administration of Taxation on the Letter Exchange between the Chinese and Italian Government Concerning Tax Clauses in the Marine Agreement Becoming Effective
Municipal taxation bureaus under the State Administration of Taxation, local taxation bureaus in each province, autonomous region, municipal and city directly under the state planning, and Yangzhou Taxation Training School,
The representatives from the Chinese and Italian Government officially exchanged letters on the tax-related clauses in the marine agreement concluded by and between the two governments on October 21, 2004. Now, the two parties inform each other by diplomatic channels that the letter exchange officially came into effect as of March 28, 2005. We now forward to you the letter. Please implement it from the date when you receive it.
April 4, 2005
The Letter from Italian Ambassador to China to Minister Zhang Chunxian
Mr. Zhang Chunxian, Ministry of Communications, P.R.C.
Dear Minister Zhang Chunxian, Oct. 21, 2004
I'm honored to mention the Marine Agreement between the Government of the Republic of Italy and the Government of the People's Republic of China, and suggest as follows: (1) amend Article 9(2) as: "the income earned by the marine companies of the contracting party from international transportation shall be exempted from the income tax and any other taxes collected by the other party"; (2) the above amendment will have no effect on any clauses and terms in the Agreement on Preventing Double Taxation of Income Tax and Tax Dogging and Evasion between the Government of the Republic of Italy and the Government of People's Republic of China signed on October 31, 1986.
If the Government of the People's Republic of China agrees on the above suggestion, I suggest this letter and your reply constitute an agreement between the two governments. Both contracting parties shall notify the other party after this letter exchange becomes effective according to relevant domestic laws in each country. This letter exchange shall come into effect as of the date when the last party receives the notification from the other party.
Best Wishes,
Menegatti, Ambassador Extraordinary and Plenipotentiary
In Beijing
Reply from Minister Zhang Chunxian to Italian Ambassador to China
Menegatti, Ambassador Extraordinary and Plenipotentiary from Republic of Italy to the People's Republic of China
Dear Ambassador Menegatti, Oct. 21, 2004
I'm honored to receive your letter today as follows:
"I'm honored to mention the Marine Agreement between the Government of the Republic of Italy and the Government of People's Republic of China, and suggest as follows: (1) amend Article 9(2) as: "the income earned by the marine companies of the contracting party from international transportation shall be exempted from the income tax and any other taxes collected by the other party"; (2) the above amendment will have no effect on any clauses and terms in the Agreement on preventing double taxation of income tax and tax dogging and evasion between the Government of the Republic of Italy and the Government of People's Republic of China signed on October 31, 1986.
If the Government of People's Republic of China agrees on the above suggestion, I suggest this letter and your reply constitute an agreement between the two governments. Both contracting parties shall notify the other party after this letter exchange becomes effective according to relevant domestic laws in each country. This letter exchange shall come into effect as of the date when the last party receives the notification from the other party.
Best Wishes, "
The Government of the People's Republic of China accepts the above suggestion.
Best Wishes,
Zhang Chunxian, Minister of the Ministry of Communications, P.R.C.
April 4, 2005
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