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Holder just isn’t eligible for the advantages of the United States-PRC revenue tax treaty, or fails to make the election to treat any achieve as overseas source, then such U.S. Holder could not be able to use the international tax credit score arising from any PRC tax imposed on the disposition of the ADSs or ordinary shares unless such credit can be utilized in opposition to United States federal earnings tax due on other income derived from international sources in the same earnings category . Holder is advised to consult its tax advisor regarding the tax penalties if a overseas tax is imposed on a disposition of the ADSs or ordinary shares, together with the availability of the overseas tax credit score underneath its explicit circumstances. international tax credit score purposes, dividends paid on our ADSs or odd shares generally shall be treated as earnings from international sources and customarily will represent passive category income. In the occasion that we are deemed to be a PRC resident enterprise underneath the PRC Enterprise Income Tax law firm Liechtenstein, a U.S.

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