Before reductions for investors who benefit from existing tax treaties, the US currently withholds 30 per cent. Even before its cut, China took just 10 per cent. 不考虑对受益于现行税制投资者的税收减免,美国目前的预提所得税率为30%。而中国的预提所得税率在此次下调之前也仅为10%。
Concessions under tax treaties 税收协定规定的特惠待遇
The Controlled Foreign Company regime is viewed as an important anti-avoidance measure, but whether it is compatibility with tax treaties or not is a important issue. 受控外国公司税制作为一种重要的反避税措施,也产生了与税收协定的兼容性问题。
Richard Irvine, a tax partner for PwC based in Bermuda, said there were several pieces of US legislation in the pipeline that could adversely affect companies based in countries that did not have tax treaties with the US in place. 普华永道(pwc)驻百慕大税务合伙人理查德欧文(richardirvine)表示,对那些把总部设在未与美国签署税收协定的国家的企业来说,美国正在制订的数项法规可能会造成不利影响。
The Department of justice will not be placated; tax treaties with Britain, Germany and Austria that preserve bank secrecy may well be torpedoed by Swiss citizens in a referendum planned for November. 美国司法部不会那么好说话;与英国、德国和澳大利亚达成的保留银行业保密原则的税务条约很可能会被计划在11月进行的瑞士公投所破坏。
Like the withholding tax imposed on dividends, the branch profits tax is subject to reduction or elimination pursuant to the terms of applicable tax treaties. 如同就股息征收的扣缴税一样,分支机构利润税也可以根据相关税收条约的条款予以扣除或免除。
International tax co-ordination depends on treaties based on a model devised 80 years ago. 国际税收协调依赖的协定是以80年前设计的一个模式为基础的。
Tax payers have the right to manage tax payment matters according to related tax treaties or agreements signed between our government and foreign governments. 纳税人有按我国政府与外国政符签订的有关税收条约、协定办理纳税事项的权利。
However, the tax exemption will shall apply to those spare parts used for the maintenance and repair purpose for of foreign transportation vehicles as stated in the international treaties acceded to by PRC the people's Republic of China or bilateral agreements signed between Chinese and foreign governments. 但中华人民共和国参加的国际条约或者与外国政府签订的双边协定中,规定对外国的运输工具维修用零部件予以免税的除外。
The author in the end conceives the framework of China's CFC legislation, and renders his suggestions on how to resolve contradictions between the future CFC legislation and tax treaties. 笔者对中国以后的CFC立法进行了构想,同时对如何解决中国所创立的CFC立法与中国所签订的税收协定之间的冲突,提出了一些自己的看法。
International Tax Treaties and Anti-tax-evasion 国际税收协定与反避税
Fair implementation of tax treaties can not only facilitate taxpayers to enjoy preferential tax policies and avoid double taxation but also contribute to protecting national tax benefits. 税收协定工作执行的好坏直接影响税收优惠政策及避免双重征税的落实,同时,对维护国家税收权益、防止国家税款的流失起着重要的作用。
To improve the procedure of tax treaty dispute settlement and accelerate the development of foreign economic, it is necessary to introduce the arbitration procedure in our country's tax treaties, and it is also feasible. 为完善对外税收协定争议解决机制与促进对外经济的发展,我国也应在税收协定中订立仲裁条款,经研究,这也是可行的。
An Analysis on the Restrictive effect Principle in Applying Tax Treaties 简析税收协定适用上的消极作用原则
Tax Treaties Are Not Absolutely Prior to Domestic Tax Laws 税收协定优于国内税法适用不可绝对化
This article argues that tax treaties have another important objective besides avoiding double taxation of income tax. 税收协定除对所得消除双重征税外,还有防止偷逃税(财政逃避)的重要目的。
Tax Sparing Clauses in International Tax Treaties 国际税收协定中饶让抵免条款问题研究
Some Thoughts on Issues concerning the Implementation of Tax Treaties 税收协定执行中存在的问题与对策
On Introducing the Arbitration Procedure In Our Country's Tax Treaties 我国对外税收协定仲裁条款引入问题初探
In practice, both China and UK have made use of articles of anti-abuse tax treaty in their tax treaties with some other countries. Whether China and UK will solve the problems of abusing tax treaty and how deserves keeping an eye on. 中英两国在实践中同其他国家都有在税收协定中加入反滥用税收协定条款的作法,中英两国在税收协定谈判中对此问题是否解决、如何解决都很值得期待。
Besides, with the rapid development in domestic and international markets, our country has no other choices but takes part in the global economic activities in a positive manner and seeks to conclude more tax treaties with other countries. 另外,随着经济全球化的发展,我国更多地参与世界经济活动,同外国缔结的双边税收协定也与日俱增。