A Study On Foreign Tax Credit Legal System

Foreign tax credit legal system is an important method accepted widely by international society to resolve the international double taxation. This article studies the essential theory of foreign tax credit legal system and discusses some problems in the applying process of foreign tax credit legal system with expatiating the author's opinions. After referring the perfect experience and theory of developed countries this dissertation also studies how to prove the foreign tax credit legal system of our country. There are five chapters in this article as following:Chapter 1 is introduction. This chapter studies on the concept of international double taxation that the foreign tax credit legal system is going to resolve. Based on it, there is a comparative study about the methods of revolving international double taxation and the study emphasizes the superiority of foreign tax credit legal system.Chapter 2 is a study on direct credit and indirect credit legal system. At first this chapter dissertates the eligibility of taxpayer and the foreign tax allowable to credit under the foreign tax credit legal system. Then illustrates the applicable condition and calculating measures of indirect credit system and analyzes a question and solution about applying the indirect foreign tax credit. At last discusses the necessity of constituting foreign tax credit system in our country.Chapter 3 is a study on full credit and ordinary credit legal system. There is a comparative study about full credit and ordinary credit system in this chapter. Then dissertates the limitation of credit in detail and compares the overall limitation and per country limitation. At last illustrates the regulation of the ordinary credit of our state.Chapter 4 is a study on international tax sparing credit legal system. This chapter discourses upon the background of tax sparing generating and calculating measures. Expatiates practice of international tax sparing credit and some factor impacting it. Last elucidates the attitude we should hold concerning the practice of international tax sparing credit in modern international political and economic conditions.Chapter 5 is conclusion. This chapter summarizes the important contents in the above chapters and expatiates the author's opinions.