english税收管辖权.ppt

INTERNATIONAL TAXATION 国 际 税 收 International Taxation Chapter Two Tax Jurisdiction-1 Outlines 1 review 2 what is Tax Jurisdiction? 3 principles of tax jurisdiction (territoriality/personality) 4 three types of tax jurisdiction 5 some typical tax jurisdiction cases in several countries 6 tax resident 7 source of income 8 related theories and practices in China Part 1 Review (1) :essence: taxation relationship (2) :taxation relationship:1 distribution relationship/2 coordination relationship Part 1 Review (3) :contents:1 overlapping or conflicting jurisdictions 2 international double taxation and its elimination 3 international tax avoidance 4 international tax treaties 5 international taxation coordination 6 international taxation competition (4) :core issues : jurisdictions/ international double taxation and its elimination / international tax avoidance / international tax treaties and international taxation coordination PART 2 what is Tax Jurisdiction? background: globalizaion elements flow(eg….) profit tax The tax jurisdiction defines the tax authority to which taxes must be paid. part of sovereignty PART 2 what is Tax Jurisdiction? Many problems concerning international taxation derive from tax jurisdicition. Two core issues: double taxation and tax avoidance one derivative issue: taxation treaties Another core issue: International taxation competition and coordination PART 3 principles of tax jurisdiction 　 territoriality principle: my zone / territory under ones control personality principle : my people PART 4 three types of tax jurisdiction 　 1 source of income jurisdiction 2 resident jurisdiction 3 citizen jurisdiction PART 4 three types of tax jurisdiction 　 resident jurisdiction citizen juri