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June 26, 2026

Agreement between the Government of the State of BAHRAIN and the Government of the People's Republic of CHINA Concerning Reciprocal Exemption from Taxation on Income Arising from International Transportation by Air Transport Enterprises

The Government of the State of Bahrain and the Government of the People's Republic of China, in accordance with the principles of equality and mutual benefit have reached to an agreement for reciprocal exemption from taxation on income arising from international transportation by air transport enterprises as follows:

Contents

Article I - Definitions

Article II - Exemption from Tax on Income from International Transportation

Article III - Income and Profits from International Transportation

Article IV - Gains from Alienation of Property

Article V - Additional Exemptions

Article VI - Catering on Board

Article VII - Employee Remuneration

Article VIII - Tax Refunds

Article IX - Consultation

Article X - Entry into Force and Termination

Article I
Definitions

For the purposes of this Agreement :

  1. The terms "a Contracting State" and "the other Contracting State" mean the Government of the State of Bahrain (hereinafter referred to as "Bahrain") or the Government of the People's Republic of China (hereinafter referred to as "China") as the context requires.

  2. The term "air transport enterprise", as the context requires, means respectively :

    1. in the case of Bahrain, Gulf Air designated by the Government of Bahrain or any other air transport enterprise carried on by a partnership or corporation created under the laws of Bahrain and managed and controlled in Bahrain; and

    2. in the case of China, China Eastern Airlines designated by the Government of China or any other air transport enterprises carried on by a resident company created under the laws of China and managed and controlled in China.

  3. The term "the business of international transportation" means the business of transporting international passengers, luggage, livestock, goods and mails carried on by an air transport enterprise of a Contracting State, and includes the sale of tickets or similar documents for such transportation such as airway bill, documents of advertising nature and gifts.

  4. The term "competent authority" means

    1. in the case of Bahrain, the Ministry of Finance and National Economy or its authorised representative;

    2. in the case of China, the State Administration of taxation or its authorised representative.

Article II
Exemption from Tax on Income from International Transportation