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法規名稱: SUPPLEMENT TO THE "CONVENTION BETWEEN THE REPUBLIC OF CHINA AND THE REPUBLIC OF PARAGUAY FOR THE AVOIDANCE OF DOUBLE TAXATION AND THE PREVENTION OF FISCAL EVASION WITH RESPECT TO TAXES ON INCOME"
簽訂日期: 民國 97 年 03 月 06 日
生效日期: 民國 97 年 06 月 03 日
簽約國: 拉丁美洲及加勒比海地區 > 巴拉圭
沿革:
1.Signed on March 6 and 3, 2008; Entered into Force on June 3, 2008

 
N.R. N° 1/08

Asuncion, 3 day of March, 2008

Excellency,

With reference to the "Convention between the Republic of
Paraguay and the Republic of China for the Avoidance of Double
Taxation and the Prevention of Fiscal Evasion with respect to
Taxes on Income", signed in the City of Asuncion on the 28th day
of April, 1994 by our two countries, I am honoured to propose
hereby to Your Excellency, the amendment of the wording in
Spanish version in paragraph 2, Article 10 to have consistency
in Spanish, Chinese and English versions would thus read as
follows:

"2. However, such dividends may also be taxed in the Contracting
State of which the company paying the dividends is a resident,
according to the laws of that State, but if the recipient is the
beneficial owner of the dividends, the tax so charged shall not
exceed 5 per cent of the gross amount of the dividends.

This paragraph shall not affect the taxation of the company in
respect of the profits, out of which the dividends are paid. "

If the above mentioned is agreeable to the Government of the
Republic of China (Taiwan), this Note and the reply from Your
Excellency stating approval, shall represent a Supplement to the
aforementioned Convention signed between the Government of the
Republic of Paraguay and the Government of the Republic of China
(Taiwan) on April 28, 1994. The Convention shall enter into
force from the date of last notice both in writing and through
diplomatic channels by Contracting Parties to each other of the
compliance with their respective internal requirements for said
purpose.


I take this opportunity to renew to your Excellency the
assurances of my highest consideration.



Ruben Ramirez Lezcano
Minister of Foreign Affairs

To His Excellency
Mr. David C. Y. Hu
Ambassador of the Republic of China (Taiwan)
Present





C.E. N° 2008-101

Asuncion, March 6, 2008

Excellency,

With reference to the note N.R. Nr. 1/08 dated March 3, 2008,
from Your Excellency, about the 'Convention between the Republic
of China and the Republic of Paraguay for the Avoidance of
Double Taxation and the Prevention of Fiscal Evasion with
respect to Taxes on Income', signed in the City of Asuncion on
the 28th day of April, 1994 by our two countries, I am honoured
to notify Your Excellency, on behalf of the Government of my
country, the agreement with the proposal of Your Excellency on
the amendment of the wording in Spanish version in paragraph 2,
Article 10 to have consistency in Chinese, Spanish and English
versions would thus read as follows:

… "2. However, such dividends may also be taxed in the
Contracting State of which the company paying the dividends is a
resident, according to the laws of that State, but if the
recipient is the beneficial owner of the dividends, the tax so
charged shall not exceed 5 per cent of the gross amount of the
dividends.

This paragraph shall not affect the taxation of the company in
respect of the profits, out of which the dividends are paid"…


...///2



H. E. Ambassador Ruben Ramirez Lezcano
Minister of Foreign Affairs
Asuncion
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