The obligation set out in the above sentence is subject to the restrictions set out in paragraph 3, but in any event such restrictions shall not be interpreted in such a way as to allow a party to refuse to provide information solely because there is no tax interest in such information to that party. However, advantageous tax rates are not available where the main purpose or one of the main purposes of a person who is involved in the creation or assignment of shares or other rights or rights of licence or provision of services is to use those items through such an agreement. This is similar to the main purpose test (PPT) in the MLI. 2. Without prejudice to paragraph 1, remuneration received by a resident of one Contracting Party for employment in the other Party shall be taxable only in the first Contracting Party if: 3. Taking into account Article 2(5) (Taxes covered) of the Agreement, the concept of `penalty or interest` shall be considered to cover any amount in the case of the Hong Kong Special Administrative Region: which, due to a delay, is added to the Hong Kong Special Administrative Region tax and is therefore recovered, and “additional taxes” pursuant to Section 82A of the Inland Revenue Ordinance (Chapter 112 of the Laws of Hong Kong). .