本教材考察了體現(xiàn)于眾多稅收條約和國內(nèi)法的連貫一致的國際稅收體系，以及其作為國際法重要組成部分的路徑，無論是基于條約還是基于慣例。其實踐性內(nèi)涵還在于：各國不能任意它們喜歡的國際稅收規(guī)則，而只能在國際稅收體系的背景下運作。當國際法隨時間的遷移發(fā)生變化時，這個體系也會同樣發(fā)生變化。因此，單邊行動雖然不是沒有可能，但是也會受到限制，各國通常都不愿采取違反這個體系基本準則的單邊行動，闡釋了國際稅收體系的結(jié)構(gòu)，也詳盡分析了美國稅法如何體現(xiàn)其根本準則。
Preface
This textbook on international tax law follows the common pattern of similar works in the field, that is, to provide an introductory analysis of the issues about how a country (eg, China) should design its income tax rules and coordinate those rules with the income tax systems of its trading partners (eg, US or EU), and what taxpayers should keep in mind when they pay income taxes transnationally under such rules and systems However, the work tries to feature a balance between ‘introduction’ and ‘inspiration’ To do this, the work pays special attention to four interconnected factors
First, the target readers The work is especially intended for students with backgrounds in laws, international politics and/or international economics Therefore, it encourages and shows how to apply the critical thinking based on the observation of international tax rules through the prism of international politics and economics Second, the focus of the discussion The work does not focus on technical details; especially, it is not a manual for international double taxation relief or international tax planning To know ‘what’ and ‘how’ is of course important, but knowing ‘why’ is often more fundamental The work emphasises the underlying principles and general framework of international taxation By learning such principles and framework, the students need not worry that their knowledge will soon be outdated with any updates of the tax rules and practices Third, local thinking The domestic tax systems in different countries vary widely to suit their economic, social and political needs Against the background of discussing the underlying principles, the general framework, and common practice of major rulesupplying countries, the work has a dedicated chapter on Chinese income tax rules which will make it easier to get the full picture of Chinas international taxation administration Fourth, selflearning Besides cases and illustrations pertinent to different situations, the work attaches some questions (most are open questions) to different parts for readers further thinking These questions are especially designed for the target students
Nevertheless, this work would also be helpful to anyone who is interested in international business transactions and wants an overview of the legal rights and duties as an international taxpayer and the most frequent method for resolving taxation disputes at international level Please note that the author is not engaged in rendering legal or other professional advice and this work is not a substitute for the advice of an attorney If you require legal or other expert advice, you should seek the services of a competent attorney or other professional
The author has used his best endeavours to ensure that the URLs for websites referred to in this work are correct However, the author has no responsibility for the websites and can make no guarantee that a site will remain live or that the content is or will remain appropriate
國際稅法
Preface
Acknowledgements
The author would like to thank Professors Zhang Lantao, Fu Kajia, Zhang Shiquan, Wu Xiangying and Tao Jian from University of International Relations, Beijing (UIR), Prof Wang Jun from University of International Business and Economics, Beijing (UIBE), and undergraduate students of UIR and international students of UIBE whoever took this class
Dedication
The work is dedicated to my family
Chen Weiguo
Beijing, 25 June 2015
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