POSITIONS ON ARTICLE 28

(MEMBERS OF DIPLOMATIC MISSIONS AND CONSULAR POSTS)

AND ITS COMMENTARY

1. Considering that Hong Kong, China is not a sovereign state but a special administrative region of the People’s Republic of China, Hong Kong, China reserves the right to replace “diplomatic missions” by “government missions” in this Article.

(Added on 22 July 2010 see History)

HISTORY

Paragraph 1: Added on 22 July 2010 by the report entitled the “2010 Update to the Model Tax Convention” adopted by the OECD Council on 22 July 2010.