税收政策基本问题的留学生作业 [3]
论文作者:英语论文论文属性:课程作业 Coursework登出时间:2014-09-23编辑:zcm84984点击率:11981
论文字数:3782论文编号:org201409211321023902语种:英语 English地区:加拿大价格:免费论文
关键词:Law Essay双重税收税收政策税收系统
摘要:本文是一篇税收政策的基本问题的留学生作业,历史上和行政方面的税收和税收系统、税收和税务系统已经超出记忆的限制而存在着。它一直都是整个有组织的社会中,历史、社会和行政的发展的驱动力。
double taxation on the same income and to determine which country has the right to tax income of particular types and particular origin. Double taxation treaties also provide for the exchange of information between revenue bodies and mutual assistance in collecting tax. [7]
The Fiscal Committee of the Organisation for European Economic Co-operation (OEEC), which later became the OECD, published a draft instalment of how a model treaty on international taxation might look. The global economy was starting to become more integrated in the 1950s and the intention was to assist businesses and governments by helping to avoid double taxation and to prevent tax evasion. The question to resolve was straightforward enough: how would governments claim their rightful taxation from mounting international businesses, while not leaving corporations worried about being unfairly taxed across the different jurisdictions in which they operate? Today there are more than 3,000 tax treaties in force around the world based on the OECD model [8] .
Quite simply, the OECD model has ascertained itself as the means of resolving the most widespread problems that arise in the field of international taxation. By facilitating a certain harmonisation of double tax treaties, it steers bilateral negotiations and helps settle disputes on a uniform basis. Considering a hypothetical example on double taxation, if a US company sells its products in the US and derives income from this activity, it will pay taxes in the US. If the same company sells its products also in France, it may well have to pay tax on the same income both in France and in the US. But how much tax should the company pay and to which tax authority? The detrimental effects of getting this double taxation wrong on international trade, investment and confidence are self-evident. Clearly, neither business nor government wants to be out of pocket or feel discouraged or discriminated against. Double tax treaties help resolve these conundrums by providing agreed rules for allocating taxing rights on cross-border income between the two countries, so that the US company is free from double taxation on its income [9] .
The OECD Model Tax Convention helps resolve such problems, though it is not binding by law. Rather, the OECD issues a recommendation based on the common position of its members, who in turn commit to follow the model and its commentaries, while taking on board its reservations, when concluding or revising bilateral tax treaties. The extensive and regularly updated explanations that accompany the model provide guidance on the acknowledged interpretations of the main text and have come to serve as a very useful reference to taxpayers, tax administrations and the courts, whether in OECD member countries or elsewhere around the world’ [10] .
1.2.1 BILATERAL TREATY [11]
Bilateral agreements sprung into being as a result of past occurrences which revealed that independent measures may perhaps not be adequate to lessen the burdens of double taxation. This shortfall stems from the multiplicity of tax systems, which in turn originates from differences among countries in legal and tax records, financial policy, revenue needs and the level of compliance and enforcement. These distinctions are reflected in the way that a country takes the support of foreign venture, the categorization and working out of taxable income and the diverse tec
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