国际税收 总复习.ppt

1 国 际 税 收 International Taxation PART 1 what is international taxation International taxation refers to the global tax rules that apply to transactions between two or more countries (also called States) in the world. It encompasses all tax issues arising in the transnational transactions. ------- partly from Roy Rohatgi Basic international taxation PART 2 essence of international taxation　 The essence of international taxation is the taxation relationship between two or more countries. 1 distribution relationship 2 coordination relationship PART 3　something we should make clear in understanding this concept　　 PART 4　difference between the concept of INTERNATIONAL TAXATION and others (1) Taxation concerning Foreigners (2) Foreign Taxation (3) National Taxation (4) Taxation Laws 2 PART 2 what is Tax Jurisdiction? background: globalizaion elements flow profit tax The tax jurisdiction defines the tax authority to which taxes must be paid. part of sovereignty PART 3 three types of tax jurisdiction 　 1 source of income jurisdiction 2 resident jurisdiction 3 citizen jurisdiction PART 5 some typical tax jurisdiction cases in several countries 　 There are three patterns of tax jurisdiction for each country to choose based on source of income jurisdiction. 1 source of income jurisdiction ：LATIN AMERICA and Africa/HK (to attract foreign capital ) tax heaven 2 source of income jurisdiction + resident jurisdiction: most of the countries around the world including China. reason: Haier’ branch of Chinese company in USA, China can not tax it only according to source of income jurisdiction 。 3 source of income jurisdiction + resident jurisdiction + citizen jurisdiction: USA PART 5 some typical tax jurisdiction cases in several countries 　 PART 6　tax resident　 PART 6　tax resident　 THINK 1 阿丘 is from CHINA and he was present