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- 1. This Agreement shall apply to taxes on income imposed on behalf of a Contracting Party or of its political subdivisions or local authorities, irrespective of the manner in which they are levied.
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- 2. 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 capital appreciation.
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- 3. The existing taxes to which this Agreement shall apply are:
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- (a) in the case of the Hong Kong Special Administrative Region:
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- (i) profits tax;
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- (ii) salaries tax; and
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- (iii) property tax;
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- whether or not charged under personal assessment;
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- (b) in the case of the United Kingdom:
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- (i) the income tax;
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- (ii) the corporation tax; and
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- (iii) the capital gains tax.
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- 4. This Agreement shall apply also to any identical or substantially similar taxes that are imposed after the date of signature of this Agreement in addition to, or in place of, the existing taxes, as well as any other taxes falling within paragraphs 1 and 2 of this Article which a Contracting Party may impose in future. The competent authorities of the Contracting Parties shall notify each other of any significant changes that have been made in their taxation laws.
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- 5. The existing taxes, together with the taxes imposed after the signature of this Agreement, are hereinafter referred to as ‘Hong Kong Special Administrative Region tax’ or ‘United Kingdom tax’, as the context requires.