国际税收课后习题答案

Chapter1

is International TaxWhat does it mainly address(探讨)

International Tax is a science focusing on a serious tax issues resulting from different and conflicting

tax rules made by particular countries ,jurisdictions and resolutions(决议).

International tax in a board sence covers not only income but also turnover taxes,etc.

about differences between China and USA on taxation system

1)The USA is a country with income taxes as a major tax while in China we have turn over taxes as

our important taxes.

2)The federal government,state government and local government of the USA have pretty rights

to collect taxes,while the rights to collect taxes are mostly controlled in central government.

3)The USA use comprehensive income tax system and deduct fees refers to different

use itemized income tax system.

4)In the respect of estate tax, real estate tax is the mainly object to be taxed .

differences among Macau,China Continent and HongKong for the purpose of tax features

according to table 1

1)The corporate income tax rates in China Continent is the highest in these three ,to 25%.

The tax base of China Continent Is worldwide while the others are territorial.

2)In China Continent we have taxes for interest,royalties,technical fees,management fees (all of

them are 10% for non-resident,20%for resident ),while the others don’t have them.

3)China Continent have value-added tax ,while the others don’t have them.

differences among UK,China Continent and Spain for the purpose of Corporate income tax

according to table 2

1)Spain has the highest corporate tax rate to 32.5%.

2)UK doesn’t tax for many income which China Continent or Spain will tax such as Capital

gains ,branch profits,dividends, technical fees and management fees.

differences among China Continent and foreign jurisdictions for the purpose of withholding

taxes according to table 3

1)For branch profits, interest ,technical fees and management fees most jurisdictions don’t collect

tax except Ireland(collect for interest) and China Continent.

2)Except Switzerland federal tax rates of dividends and interest are 35% and higher than China

Continent ,other jurisdictions’ withholding tax rates are mostly lower or equal to China Continent.

Chapter2

International Income Taxation

does a country generally design its income taxation system

(book page50)

1)territorial(领土模式）：

2)Residency(属人模式）:

tax on the worldwide income of residents, and impose tax on the income of nonresidents from

certain sources within the country. USA.

3)Exclusion(例外）:

specific inclusion or exclusion of certain amounts,classes,or items of income in/from the base of

taxation.

4)Hybrid(混合模式):

some governments have chosen for all or only certain classes of taxpayers, to adopt systems that

are a combination of territorial, residency, or exclusionary.

is it important to make clear source of income

To make clear source of income is important because it decidides that whether a individual or

corporation should pay tax in a country and what credits can it enjoy.

explanation:Thin Capitalization;Foreign tax Credit;Withholding tax; International tax treaty;

Deferral system; International transfer pricing

Thin Capitalization:

Thin capitalization is a method that taxpayers borrow too much money from oversea related party

and pay much interest, so that they can enjoy much deduction before this way,they transfer

profits from high tax burden countries to low tax burden countries or jurisdictions.

Foreign tax Credit（外国税收抵免）：

If you paid or accrued foreign taxes to a foreign country on foreign source income and are subject

to resident country tax on the same income, you may be able to take a credit for those taxes.

Taken as a credit, foreign income taxes reduce your own country tax liability.

Withholding tax:

Withholding tax is tax withheld by the country when a corporation making a payment to its resident

country , in which the full amount owed to that corporation is reduced by the tax withheld.

International tax treaty:

International tax treaty is a treaty a country (or jurisdiction) signed with other countries (or

jurisdiction) for affairs about taxation.

Deferral system：

Deferral system is a tax incentive (激励措施)to encourage domestic tax residence to make

investment broad.

But it may cause international tax avoidance.(缺点：可能造成国际避税)

International transfer pricing:

International transfer pricing is a very important way for multinational company to avoid

international tax.

Transfer pricing refers to a kind of non-market pricing action taken by related corporations to shift

profits form high tax rate countries or jurisdictions to low tax rete regions.

Chapter3

Tax Residence

is the main difference between a tax resident and a non-tax resident for tax liability purpose

In general, a tax resident bears infinite tax liability ,should pay tax for all of its income.

A non-tax resident bears limited tax liability, should pay tax for income sourced from the country.

you name some tests in determining whether a person is a resident

for corporation:

place-of-incorporation test,place-of-management test,residence of the shareholders test

for individiual:

a fact-and-circumstances test ;abode test; number of day test(in China:1~5year – temporary

resident,>5year - long-term resident)

an example to prove how different countries apply differing tests to judge a person's

residence

For example ,

China for individual:domicile test,number of days(a full year);