财政部税务总局(88)财税协字第002号1988年1月13日关于执行避免双重征税协定(以下简称“税收协定”)的条文解释以及需要具体明确的问题,总局曾先后行文作了解释说明。但从各地的反映来看,对一此具有普遍性的条文还需要进一步明确,对同个别国家的税收协定中的有此特殊条款的解释也还需要补充说明。现根据去年十二月全国涉外税收工作会议讨论的意见,对若干条文解释和享受税收协定待遇的报批手续明确如下: Ministry of Finance, State Administration of Taxation (88) Finance and Taxation Association No. 002 January 13, 1988 With regard to the interpretation of the provisions on the implementation of the agreement on the double taxation avoidance (hereinafter referred to as the “tax agreement”) and the specific issues that need to be clarified, explain. However, judging from all over the world, there is still a need to further clarify the provisions that are universal in this regard. The explanation of this special clause in the tax treaties with other countries also needs to be supplemented. Now based on the opinions discussed in the national taxation conference on foreign affairs in December last year, the procedures for approval of the interpretation and enjoyment of the treatment of tax treaties in certain articles are as follows: