AGREEMENT BETWEEN THE GOVERNMENT OF THE REPUBLIC OF CAMEROON AND THE GOVERNMENT OF THE PEOPLE'S REPUBLIC OF CHINA FOR THE ELIMINATION OF DOUBLE TAXATION WITH RESPECT TO TAXES ON INCOME AND THE PREVENTION OF TAX EVASION AND AVOIDANCE
The Government of the Republic of Cameroon and the Government of the People's Republic of China,
Desiring to further develop their economic relationship and to enhance their cooperation in tax matters,
Intending to conclude an Agreement for the elimination of double taxation with respect to taxes on income without creating opportunities for non-taxation or reduced taxation through tax evasion or avoidance (including through treaty-shopping arrangements aimed at obtaining reliefs provided in this Agreement for the indirect benefit of residents of third States),
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.
- For the purposes of this Agreement, income derived by or through an entity or arrangement that is treated as wholly or partly fiscally transparent under the tax law of either Contracting State shall be considered to be income of a resident of a Contracting State but only to the extent that the income is treated, for purposes of taxation by that State, as the income of a resident of that State.
- This Agreement shall not affect the taxation, by a Contracting State, of its residents except with respect to the benefits granted under paragraph 2 of Article 9, paragraph 3 of Article 18, and Articles 19, 20, 21, 23, 24, 25 and 28.
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ARTICLE 2
TAXES COVERED
- This Agreement shall apply to taxes on income imposed on behalf of a Contracting State or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.
- 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, and taxes on the total amounts of wages or salaries paid by enterprises.
- The existing taxes to which the Agreement shall apply are in particular:
a) in Cameroon: (i) the personal income tax plus surcharges; (ii) the company tax plus surcharges; (iii) the minimum tax on companies and individuals plus surcharges; (iv) the special tax on income paid to persons resident out of Cameroon; and (v) the taxes for land loans and other taxes based on salaries;
(hereinafter referred to as “Cameroon tax”).
b) in China: (i) the individual income tax; (ii) the enterprise income tax;
(hereinafter referred to as “Chinese tax”);
- The Agreement shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of the Agreement in addition to, or in place of, the existing taxes. The competent authorities of the Contracting States shall notify each other of any significant changes which have been made in their taxation laws.