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June 26, 2026

The 2013 Protocol amends the 2002 DTAA between Bahrain and China. Key modifications include updating the definition of 'Chinese tax' (Article 1) and 'resident of a Contracting State' (Article 3). It introduces a 10% maximum tax rate on dividends paid to a beneficial owner who is a resident of the other State (Article 4). For the elimination of double taxation in China, the Protocol specifies the application of a credit method (Article 6). Crucially, it replaces Article 26 with a comprehensive framework for the exchange of information to combat fiscal evasion, extending to data held by financial institutions.

Protocol to the Agreement between the Government of the KINGDOM OF BAHRAIN and the Government of the PEOPLE'S REPUBLIC OF CHINA for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income

The Government of the Kingdom of Bahrain and the Government of the People's Republic of China,

Desiring to conclude a Protocol to amend the Agreement between the Government of the Kingdom of Bahrain and the Government of the People's Republic of China for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income signed at Beijing on 16 May 2002 (hereinafter referred to as 'the Agreement'),

Have agreed as follows:

Contents

Article 1

Article 2

Article 3

Article 4

Article 5

Article 6

Article 7

Article 8

Article 9

Article 1

The existing sub-paragraph (a) of paragraph 3 in Article 2 of the Agreement shall be deleted and replaced by the following:

'(a) in China:

the individual income tax;
the enterprise income tax; (hereinafter referred to as 'Chinese tax');'

Article 2

The existing sub-paragraph (j) of paragraph 1 in Article 3 of the Agreement shall be deleted and replaced by the following:

'(j) The term 'competent authority' means, in the case of China, the State Administration of Taxation or its authorized representative, and in the case of Bahrain, the Minister of Finance or his authorized representative.'

Article 3

The existing paragraph 1 in Article 4 of the Agreement shall be deleted and replaced by the following:

'1. For the purposes of this Agreement, the term 'resident of a Contracting State' means any person who, under the laws of that Contracting State, is liable to tax therein by reason of his domicile, residence, place of incorporation, place of effective management or any other criterion of a similar nature. This term, however, does not include any person who is liable to tax in that State in respect only of income from sources in that State.'

Article 4

The existing paragraph 2 in Article 10 of the Agreement shall be deleted and replaced by the following: