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International tax sparing credit system research

Author: YangYing
Tutor: FanJing
School: Yantai University
Course: International Law
Keywords: Tax sparing credit Reassessment Objective evaluation Tactics
CLC: F812.42
Type: Master's thesis
Year: 2009
Downloads: 245
Quote: 1
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Abstract


Tax sparing credit system means that tax breaks are not actually paid part of the tax deemed to have been paid the same to grant credits for the country of residence of its residents due to the country of origin. The principle of subsidiarity, it is the development of the credit system is an important system in international tax law, it is usually a tax sparing credit terms agreed upon in the bilateral tax treaty. This system to make up for the credit system in the process of settlement of international double taxation arising from the defect, so that the preferential tax policies of the host country in the international investment to real practical results, and play an incentive for investors. Since the 1990s, however, many countries, especially developed countries, requires some additional conditions, increasing sparing provisions limit or cancel the voice, in this context, the Organization for Economic Cooperation and Development (OECD) released the terms of the evaluation report, in the field of international tax law has caused no small controversy, however different stance with the developed countries, developing countries, the system has worked hard to welcome. Whether this system should continue to exist, and still be able to service the international economic development, and so become the focus of debate. This as the starting point of the system studied and tried to combine our analyzes the problems encountered in the process of use of sparing credit terms, which raised our reasonable strategy sparing credit terms. The text is divided into four parts, about 35,000 words. The first part of sparing credit terms are summarized. This section briefly describes the concept and scope of sparing credit provisions, Rao recalled the terms of the credit for the development of history and summed up the characteristics of this system, and finally, from a different perspective and objective evaluation of this system. The second part of the tax sparing credit of the international practice. This section explains the impact of countries selected sparing Terms factors, countries on the transformation of the traditional stance of sparing credit terms as well as national attitude, which leads to the OECD to re-evaluate the necessity. The third part of the OECD tax sparing credit re-evaluate its evaluation. This section describes the OECD's position leads to re-evaluate the necessity of sparing credit terms as well as to evaluate, draw Rao Credit Terms suggestions on how to design, and a critical analysis of the views and recommendations of the OECD. The fourth part of our strategy selection sparing credit terms. This part of the focus of the article, introduced China's situation and characteristics of foreign signed sparing credit terms, summed up the problems encountered in the process of China in the use of Rao Credit Terms, the last light of China's specific national conditions systematically discusses our country in the process of Rao Credit terms should adhere to the principle of the strategy adopted.

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CLC: > Economic > Fiscal, monetary > Finance, the state's financial > China's financial > Financial income and expenditure > Tax
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