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论文作者:英语论文论文属性:学期论文 termpaper登出时间:2014-11-10编辑:zcm84984点击率:15489
论文字数:4006论文编号:org201411071254577935语种:英语 English地区:美国价格:免费论文
摘要:本文是一篇税收和税收制度的历史和管理国际法论文,税和税收制度已经存在远远超出内存限制。它一直是历史,社会和整个行政组织发展的动力。在现今的英国,与所有错综复杂的经济制度一样,税收的根本意义,可以从它的绝对的和明显的结果可以看出。
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] .
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 techniques used for apportioning income to domestic and foreign origin. Due to increasing intricacies of tax systems and the array of taxes levied, it has become more and more difficult to make provision for a fully efficient easement from international double taxation through the unilateral approach [12] .
The wrapping up of bilateral tax treaties for the avoidance double taxation came into view since 1960s as an outstanding characteristic of inter-State economic relations. As of fact, double tax conventions are now the recognized ways for States to be in one accord at the international level on the decision of double taxation predicaments that arise in imposing personal and corporate income taxes on cross-border activities of their people and nationals. Every convention is a negotiation between the domestic laws of contracting States that are parties to the convention. These negotiation and compromises undertaken by the States have come to take paradigm forms. The OECD Model treaty has been the back bone for practically all tax treaties between developed countries. It was initially published in a draft form in 1963 and finally published as the OECD Model Double Taxation Convention on Income and on Capital in 1977. [13] However, most double tax conventions are quiet about how contracting States will proffer efficacy to them. This is left as an issue for the domestic (constitutional) law of each state.
Bilateral tax treaties resolves many double taxation problems by reconciling the differences in various types of income and their geographical source, ascertaining a widespread method of determining how certain incomes shall be classified and taxed, and either assigning exclusive tax juri本论文由英语论文网提供整理,提供论文代写,英语论文代写,代写论文,代写英语论文,代写留学生论文,代写英文论文,留学生论文代写相关核心关键词搜索。