Applicability of DTAA: India-China tax treaty does not extend to Hong Kong due to HKSAR autonomy. The DTAA between India and the People's Republic of China does not automatically extend to the Hong Kong Special Administrative Region; the Sino British Joint Declaration and the Basic Law recognise HKSAR authority to conclude economic and financial agreements and financial autonomy, and the Central People's Government decides whether Chinese international agreements apply to Hong Kong after consulting the region, therefore the India-China treaty is not applicable to Hong Kong.
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Provisions expressly mentioned in the judgment/order text.
Applicability of DTAA: India-China tax treaty does not extend to Hong Kong due to HKSAR autonomy.
The DTAA between India and the People's Republic of China does not automatically extend to the Hong Kong Special Administrative Region; the Sino British Joint Declaration and the Basic Law recognise HKSAR authority to conclude economic and financial agreements and financial autonomy, and the Central People's Government decides whether Chinese international agreements apply to Hong Kong after consulting the region, therefore the India-China treaty is not applicable to Hong Kong.
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