tiea agreement between bermuda and china

8/6/2019 TIEA agreement between Bermuda and China

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AGREEMENTBETWEEN

THE GOVERNMENT OF BERMUDAAND

THE GOVERNMENT OF THE PEOPLE'S REPUBLIC OF CIDNAFOR

THE EXCHANGE OF INFORMATION RELATING TO TAXES

The Government of Bermuda and the Government of the People's Republic of China("the Contracting Parties"):

Acknowledging that the Contracting Parties are competent to negotiate and conclude atax information exchange agreement;

Desiring to provide a framework for cooperation and exchange of information in taxmatters;

Agree to conclude the Agreement as follows:

ARTICLE 1SCOPE OF AGREEMENT

1. The competent authorities of the Contracting Parties shall provide assistancethrough exchange of information that is foreseeably relevant to the administration andenforcement of the domestic laws of the Contracting Parties concerning taxes covered bythis Agreement. Such information shall include information that is foreseeably relevant tothe determination, assessment, verification and collection of such taxes, the recovery andenforcement of tax claims, and the investigation or prosecution of tax matters.

2. Information shall be exchanged in accordance with the provisions of thisAgreement and shall be treated as confidential in the manner provided in Article 8.

ART ICLE 2JURISDICTION

1. The Requested Party is not obligated to provide information which is neitherheld by its authorities nor in the possession or control of persons who are within itsterritorial jurisdiction.

2. To enable the appropriate implementation of this Agreement, information shallbe provided in accordance with this Agreement by the competent authority of theRequested Party:

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(a) without regard to whether the person to whom the information relates is aresident, national or citizen of a Party, or whether the person by whom theinformation is held is a resident, national or citizen of a Party; and

(b) provided that the information is present within the territory, or in the possessionor control of a person subject to the jurisdiction, of the Requested Party.

ARTICLE 3TAXES COVERED

1. The taxes covered by this Agreement are:

(a) in the case of the People's Republic of China:(i) the individual income tax; and(ii) the enterprise income tax;

(b) in the case of Bermuda, taxes of every kind and description.

2. The competent authorities of the Contracting Parties shall notify each other ofany relevant changes to the taxation and related information gathering measures coveredby this Agreement.

3. The taxes covered by this Agreement may be expanded or modified by mutualagreement of the Contracting Parties in the form agreed upon by both Contracting Parties.

ARTICLE 4DEFINITIONS

1. In this Agreement:

(a) "the People's Republic of China", when used in a geographical sense, means allthe territory of the People's Republic of China, including its territorial sea, inwhich the Chinese laws relating to taxation apply, and any area beyond itsterritorial sea, within which the People's Republic of China has sovereign rightsof exploration for and exploitation of resources of the seabed and its sub-soiland superjacent water resources in accordance with international law and itsdomestic laws;

(b) "Bermuda", when used in a geographical sense, means the Islands of Bermuda,including its territorial sea;

(c) "collective investment fund or scheme" means any pooled investment vehicle,irrespective of legal form;

(d) "company" means any body corporate or any entity that is treated as a bodycorporate for tax purposes;

(e) "competent authority" means:(i) in the case of the People's Republic of China, the State Administration ofTaxation or its authorized representative; and(ii) in the case of Bermuda, the Minister of Finance or an authorisedrepresentative of the Minister;

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(

(f) "information" means any fact, statement, document or record in whatever form;(g) "information gathering measures" means judicial, regulatory or

administrative laws and procedures that enable a Contracting Party to obtain andprovide the information requested;

(h) "national" means:

(i) in relation to Bermuda, a legal person who is a Bermudian deriving theirstatus as such from the laws in force in Bermuda;(ii) in relation to the People's Republic of China, any individual possessing

the nationality of the People's Republic of China;(iii) any legal person, partnership, company, trust, estate, association or any

other entity, deriving its status as such from the laws in force in aContracting Party;

(i) "person" means a natural person, a company or any entity that is treated as abody corporate for tax purposes, or any other body or group of persons;

G) "public collective investment fund or scheme" means any collective investmentfund or scheme, in which the purchase, sale or redemption of shares or otherinterests is not implicitly or explicitly restricted to a limited group of investors;

(k) "publicly traded company" means any company whose principal class of sharesis listed on a recognised stock exchange provided its listed shares can be readilypurchased or sold by the public. Shares can be purchased or sold "by the public"if the purchase or sale of shares is not implicitly or explicitly restricted to alimited group of investors; and for this purpose, the term "principal class ofshares" means the class or classes of shares representing a majority of the votingpower and value of the company and the term "recognised stock exchange"shall bear the meaning agreed upon by the competent authorities of theContracting Parties;

(1 ) "Requested Party" means the party to this Agreement which is requested toprovide or has provided information in response to a request;

(m) "Requesting Party" means the party to this Agreement submitting a request foror having received information from the Requested Party;

(n) "tax" means any tax covered by this Agreement.

2. As regards the application of this Agreement at any time by a Contracting Party,any term not defined therein shall, unless the context otherwise requires, have themeaning that it has at that time under the law of that Contracting Party, any meaningunder the applicable tax laws of that Contracting Party prevailing over a meaning givento the term under other laws of that Contracting Party.

ARTICLE 5EXCHANGE OF INFORMATION UPON REQUEST

1. The competent authority of a Requested Party shall provide upon request inwriting information for the purposes referred to in Article 1. Such information shall beexchanged without regard to whether the conduct being investigated would constitute atax offence under the laws of the Requested Party if it occurred in the territory of theRequested Party. If the information received by the competent authority of the Requested

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Party is not sufficient to enable it to comply with the request for information, it shalladvise the competent authority of the Requesting Party of that fact and request suchadditional information as may be required to enable the effective processing of therequest.

2. If the information in the possession of the competent authority of the RequestedParty is not sufficient to enable it to comply with the request for the information, theRequested Party shall use all relevant information gathering measures to provide theRequesting Party with the information requested, notwithstanding that the RequestedParty may not 'need such information for its own tax purposes.

3. If specifically requested by the competent authority of the Requesting Party, thecompetent authority of the Requested Party shall provide information under this Article,to the extent allowable under its domestic laws, in the form of depositions of witnessesand authenticated copies of original records.

4. Each Contracting Party shall ensure that its competent authority, for the purposesof this Agreement, has the authority to obtain and provide upon request:

(

(a) information held by banks, other financial institutions, and any person,including nominees and trustees, acting in an agency or fiduciary capacity;

(b) information regarding the legal and beneficial ownership of companies,partnerships, trusts, foundations and other persons, including, within theconstraints of Article 2, ownership information on all such persons in anownership chain; in the case of trusts, information on settlors, trustees, andbeneficiaries; and in the case of foundations, information on founders, members,beneficiaries and directors or other senior officers of the foundation.

5. Notwithstanding the preceding paragraphs, this Agreement does not create anobligation on the Contracting Parties to obtain or provide ownership information withrespect to publicly traded companies or public collective investment funds or schemes,unless such information can be obtained without giving rise to disproportionatedifficulties.

6. The competent authority of the Requesting Party shall provide the followinginformation to the competent authority of the Requested Party when making a request forinformation under this Agreement in order to demonstrate the foreseeable relevance ofthe information to the request:

(a) the identity of the person under examination or investigation;(b) the period for which the information is requested;(c) the nature and type of the information requested, including a description of the

information and/or specific evidence sought, and the form in which theRequesting Party would prefer to receive the information;

(d) the tax purposes for which the information is sought;

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(e) grounds for believing that the information requested is present in the territory ofthe Requested Party or is in the possession or control of a person subject to thejurisdiction of the Requested Party;

(f) to the extent known, the name and address of any person believed to be inpossession or control of the information requested;

(g) a statement that the request is in conformity with this Agreement and the lawsand administrative practices of the Requesting Party, and that if the requestedinformation were within the jurisdiction of the Requesting Party then thecompetent authority of the Requesting Party would be able to obtain theinformation under the laws of the Requesting Party or in the normal course ofadministrative practice;

(h) a statement that the Requesting Party has pursued all means available in its ownterritory to obtain the information, except those that would give rise todisproportionate difficulties.

7. The competent authority of the Requested Party shall forward the requestedinformation as promptly as possible to the competent authority of the Requesting Party.To ensure a prompt response, the competent authority of the Requested Party shall:

(

(a) confirm receipt of a request in writing to the competent authority of theRequesting Party and shall notify the competent authority of the RequestingParty of any deficiencies in the request within 60 days of receipt of the request;and

(b) immediately inform the competent authority of the Requesting Party to explainthe reasons for its inability or the obstacles or its refusal, if the competentauthority of the Requested Party has been unable to obtain and provide theinformation requested within 90 days of receipt of the request, including ifobstacles are encountered in furnishing the information, or if the competent

authority of the Requested Party refuses to provide the information.

ARTICLE 6TAX EXAMINATIONS OR INVESTIGATIONS ABROAD

1. The Requested Party may, in accordance with its domestic laws, followingreceipt of notice of a reasonable time from the Requesting Party, allow representatives ofthe competent authority of the Requesting Party to enter the territory of the RequestedParty in connection with a request to interview persons and examine records with theprior written consent of the persons concerned. The competent authorities of theContracting Parties shall agree on the time and place of the intended meeting with the

persons concerned.

2. At the request of the competent authority of the Requesting Party, and inaccordance with its domestic laws, the competent authority of the Requested Party maypermit representatives of the competent authority of the Requesting Party to be present atthe tax examination in the territory of the Requested Party.

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3. If the request referred to in paragraph 2 is granted, the competent authority ofthe Requested Party conducting the examination shall, as soon as possible. notify thecompetent authority of the Requesting Party of the time and place of the examination, theauthority or person authorised to carry out the examination and the procedures andconditions required by the Requested Party for the conduct of the examination. Alldecisions regarding the conduct of the examination shall be made by the Requested Partyconducting the examination in accordance with its domestic laws.

ARTICLE 7POSSIBILITY OF DECLINING A REQUEST

1. The competent authority of the Requested Party may decline to assist:

(a) where the request is not made in conformity with this Agreement;(b) where the Requesting Party has not pursued all means available in its own

territory to obtain the information, except where recourse to such means wouldgive rise to disproportionate difficulty; or

(c) where the disclosure of the information requested would be contrary to thepublic policy (ordre public) of the Requested Party.

2. This Agreement shall not impose upon a Contracting Party any obligation toprovide information which would disclose any trade, business, industrial, commercial orprofessional secret or trade process. Information described in paragraph 4 of Article 5shall not by reason of that fact alone constitute such a secret or process.

3. (a) The provisions of this Agreement shall not impose on a Contracting Party theobligation to obtain or provide information which would reveal confidentialcommunications between a client and an attorney, solicitor or other admittedlegal representative where such communications are(i) produced for the purposes of seeking or providing legal advice; or(ii) produced for the purposes of use in existing or contemplated legal

proceedings;(b) Information held with the intention of furthering a criminal purpose is not

subject to legal privilege, and nothing in this Article shall prevent a professionallegal advisor from providing the name and address of a client where doing sowould not constitute a breach of legal privilege.

4. A request for information shall not be refused on the ground that the tax liabilitygiving rise to the request is disputed by the taxpayer.

5. The Requested Party shall not be required to obtain and provide informationwhich, if the requested information was within the jurisdiction of the Requesting Party,the competent authority of the Requesting Party would not be able to obtain under itslaws or in the normal course of administrative practice.

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6. The Requested Party may decline a request for information if the information isrequested by the Requesting Party to administer or enforce a provision of the tax law ofthe Requesting Party, or any requirement connected therewith, which discriminatesagainst a national of the Requested Party as compared with a national of the RequestingParty in the same circumstances.

ARTICLE 8CONFIDENTIALITY

1. All information provided and received by the competent authorities of theContracting Parties shall be kept confidential and shall be disclosed only to persons orauthorities (including courts and administrative bodies) officially concerned with thepurposes specified in Article 1 and used by such persons or authorities only for suchpurposes, including the determination of any appeal. For these purposes, informationmay be disclosed in public court proceedings or injudicial proceedings.

2. The information may not be used for any purpose other than for the purposesstated in Article 1 and may not be disclosed to any other person or entity or authoritywithout the express written consent of the competent authority of the Requested Party.

ARTICLE 9SAFEGUARDS

The rights and safeguards secured to persons by the laws or administrative practices ofthe Requested Party remain applicable. The rights and safeguards shall not be applied bythe Requested Party in a manner that unduly prevents or delays effective exchange ofinformation.

ARTICLE 10ADMINISTRATIVE COSTS

Incidence of costs incurred in providing assistance (including reasonable costs of thirdparties and external advisors in connection with litigation or otherwise) shall be agreedupon by the competent authorities of the Contracting Parties.

ARTICLE 11LANGUAGE

Requests for assistance and responses thereto shall be in English.

ARTICLE 12MUTUAL AGREEMENT PROCEDURE

1. Where difficulties or doubts arise between the Contracting Parties regarding theimplementation or interpretation of this Agreement, the respective competent authoritiesshall use their best efforts to resolve the matter by mutual agreement.

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2. In addition to the endeavours referred to in paragraph 1, the competentauthorities of the Contracting Parties may mutually determine the procedures to be usedunder Articles 5 and 6.

3. The competent authorities of the Contracting Parties may communicate witheach other directly for the purposes of this Agreement.

4. The Contracting Parties may also agree in writing on other forms of disputeresolution.

ARTICLE 13ENTRY INTO FORCE

This Agreement shall enter into force when each Contracting Party has notified in writingthe other of the completion of its necessary internal procedures for entry into force. TheAgreement shall have effect in respect of taxable years beginning on or after the date ofentry into force.

ARTICLE 14TERMINATION

1. This Agreement shall remain in force until terminated by either ContractingParty.

2. Either Contracting Party may terminate this Agreement by giving notice oftermination in writing through diplomatic channels. Such termination shall become

effective on the first day of the month following the expiration of a period of six monthsafter the date of receipt of notice of termination by the other Contracting Party.

3. If the Agreement is terminated, the Contracting Parties shall remain bound bythe provisions of Article 8 with respect to any information obtained under thisAgreement. All requests received up to the effective date of termination shall be dealtwith in accordance with the terms of this Agreement.

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IN WITNESS WHEREOF, the undersigned, being duly authorised by the respectiveContracting Parties, have signed this Agreement.

11 • L .L "I I l o l . D ~ ~ L - ~ -DONE at no,,!tLi T~I\...- in duplicate this ""'" day of ~.2010, in the English and Chinese languages, both texts being equally authentic.

For the Government ofBermuda

For the Government of thePeople's Republic of China

.o n E.G . IL[ B ( nd) LEe. (U\ 3Sc (LSE)

Barrister and AttorneyNo tary Pub lic, Islan ds o f Bermuda

Dated thisG~ay orD,,,,.,20m

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tiea agreement between bermuda and china

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