国际税法chapter 7.pptVIP

International Tax Convention Made by: Kuang Ping Preface The contents of general international tax convention are extensive, which include bilateral and multilateral tax convention, general convention and special convention and so on. Nowadays, the most important international tax convention—“model convention of UN” and “model convention of OECD” is guided by the international organization and generally accepted by all countries. References International Taxation，Charles I. Kingson; Cynthia A. Blum，Citic Publishing House，2003 国际税收，杨斌，复旦大学出版社，2003 OECD税收协定范本注释，国家税务总局国际司，中国税务出版社，2000 国际税收，张志超、李月平，首都经济贸易大学出版社，2005 国际税收，朱青，中国人民大学出版社，2001 discussion Why the government must sign tax conventions with other countries? Contents Section 1: The Outline of International Tax Convention Ⅰ. The concept and classification Ⅱ. The purposes Ⅰ. International Tax Convention Tax Convention is generally called “Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income”. Since 1983, China has signed tax conventions with 82 other States successively. Till the end of 2003, 74 tax conventions have come into effect. 国际税收协定是两个或两个以上的主权国家，为了协调相互间的税收分配关系和处理跨国纳税人征税事务方面的问题，本着相互尊重主权，按照对等、互利的原则，通过政府间谈判所签订的一种书面协议。 Ⅱ. The purposes 1.to avoid and eliminate double taxation and to reach agreement on some restrictive provisions acceptable to both parties on the basis of admitting the taxation power of both countries; 2.to avoid tax discrimination and realize non-discrimination treatment, and to seek reasonable tax treatment for its residents’ investment and business in other countries; 3.to prevent cross-boundary tax evasion, that is, to strengthen the relation and cooperation among tax administrations by means of tax conventions and prevent taxpayers from transferring their profits to other countries and avoiding tax by taking advantage of loopholes（漏洞） of tax laws. Model Convention for the Avoidance of Double Taxation with Respect to