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我国政府与南斯拉夫社会主义联邦共和国议会联邦执行委员会于一九八八年十二月二日在北京签订的关于对所得和财产避免双重征税的协定,业经我国外交部与南斯拉夫外交部分别于一九八九年二月二十八日和一九八九年十一月十六日互致照会,确认双方已完成该协定生效的法律程序。根据协定第二十八条的规定,该协定自一九八九年十二月十六日开始生效,从一九九○年一月一日起执行。上述协定的文本,业经我局于一九八八年十二月二十二日以(88)国税外字第342号文检发你局。为便于执行协定,现对照协业有关条文解释如下: 一、第七条第七款规定“中国居民南斯拉夫国内联合劳动组织投资取得的利润可以在南斯拉夫征税。”和第二条第三款明确股息一语“不包括中国居民投资于南斯拉夫国内联合劳动组织取得的利润”。其含义是中国居民在南
The agreement signed between our government and the Federal Executive Council of the Federal Socialist Federal Republic of Yugoslavia in Beijing on December 2, 1988, to avert double taxation on income and property, was approved by the Ministry of Foreign Affairs of the Republic of Yugoslavia On February 28, 1989 and November 16, 1989, each note was taken to confirm that both parties have completed the legal proceedings for the entry into force of the agreement. Pursuant to Article 28 of the Agreement, the agreement came into force on December 16, 1989 and will come into effect on January 1, 1990. The text of the aforesaid agreement was seized by our bureau on December 22, 1988 and examined in (88) Document No. 342 of the State Administration of Taxation. In order to facilitate the implementation of the agreement, the relevant provisions of the contract are explained as follows: 1. Article 7, paragraph 7, stipulates that “the profit earned by the investment by the Chinese domestic Yugoslav joint labor organizations may be taxed in Yugoslavia.” And Article 2, paragraph 3, The term “dividend” does not include the profits made by Chinese residents in investing in Yugoslav domestic joint labor organizations. " Its meaning is Chinese residents in the south