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Bahrain-China

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Protocol to the Tax Treaty between Bahrain and China has Entered into Force

The Protocol to the 2002 income tax treaty between Bahrain and China entered into force on 1 April 2016. The protocol, signed 16 September 2013, is the first to amend the treaty.

Changes Made

The protocol makes the following main changes:

  • Amends Article 10 (Dividends) by increasing the withholding tax rate for from 5% to 10%;
  • Amends Article 23 (Methods for the Elimination of Double Taxation) in respect of China by adding the provision that when a resident of China directly or indirectly holds at least 20% of the capital of a Bahrain company paying a dividend, the credit for the tax paid will take into account the tax paid to Bahrain by the dividend paying company; and
  • Replaces Article 26 (Exchange of Information) to bring it in line with the OECD standard for information exchange.

The protocol also amends Article 2 (Taxes Covered) in respect of China, amends Article 3 (General Definitions) to change the meaning of the term "competent authority" in respect of Bahrain, and amends Article 4 (Resident) to expand the meaning of the term "resident of Contracting State".

Effective Date

The protocol applies from 1 January 2017.

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