TNAG-2833-FCO40-4086-Air-service-agreements-between-Hong-Kong-and-other-countries-1993 — Page 8

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FROM DTP

布政司署 香港下亞厘畢道

CONFIDENTIAL

17:28

NO.29

PAGE

GOVERNMENT SECRETARIAT

TARIA

LOWER ALBERT ROAD HONG KONG

ESBCR 12/936/89 (93) IV

By fax and by bag

本署檔號 Our Ref.:

來函檔號 Your Ref.:

6 December 1993

Ms Joanne Othick

International Aviation Directorate

Department of Transport

2 Marsham Street

London

SW1P 3EB

Dear Joame

At our

Canadians, Kong/Canada

Hong Kong/Canada ASA: Double Taxation Provisions

recent air services consultations with the they proposed the inclusion in the Hong ASA of an article on the avoidance of double taxation on airline revenue, gross profits, income or profits. I enclose a copy.

We are now considering this not only in the light of Hong Kong's taxation policy but also in terms of whether amending the ASA would be a better method of providing double taxation relief for airlines than a stand-alone Convention on Double Taxation. Our preliminary view is that for a number of reasons it would be preferable to amend the ASA as suggested. We have not, however, come across such a provision before. I will be asking my contact in the Canadian Commission in Hong Kong whether Canada has similar arrangements with its other ASA partners, but I should be grateful if you would also let me know of any UK ASA that includes a provision on double taxation. It would be very helpful if I could have your

reply by 14 December.

Should we eventually agree to amend the ASA in the manner suggested by the Canadians, we would of course seek a specific authorization for that purpose from the Hong HMG?

Kong Government and submit the amendment to the Sino-British Joint Liaison Group for processing in the normal way.

I am copying this letter to Sarah Smith in IA2.

Un end

Чт

Martin Cla

се

(Martin Glass)

Air Services Negotiations Unit Economic Services Branch

KAN? A

encl.

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