Canada Hong Kong Tax Agreement

4. The competent authorities of the Contracting Parties shall endeavour to establish by common accord any difficulties or doubts which arise in the interpretation or application of this Agreement. There have also been important developments that have influenced the Canada-China treaty. On February 19, 2012, the Canadian Prime Minister`s Office announced that Canadian and Chinese authorities had reached an agreement in principle on updating the Canada-China contract. Expected future updates to the Canada-China treaty could impact the benefits of structuring investment structures from mainland China to Canada via Hong Kong. These outbound investment structures should therefore be reviewed as soon as the draft new Canada-China treaty has been published. In the absence of a reciprocal agreement, that person shall not be entitled to an exemption or exemption from the taxes provided for in this Agreement. 2. Any doubt as to the interpretation of this paragraph shall be dispelled in accordance with Article 23(4) (mutual agreement procedure) or, in the absence of agreement in accordance with that procedure, in accordance with another procedure agreed by both parties.

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