Study On International Taxation Law On The Technology Imported

This dissertation focuses on issues of international double taxation, avoiding double tax measures, and tax sparing credit on the license fee and other related income on import technology. It takes way of analysis in practical case to demonstrate the effects of avoiding international double taxation, the affect of tax sparing credit on China's tax preferential policy for importing foreign new hi-tech. Chinese government takes full amount tax sparing credit to strengthen Chinese enterprise's competitive power in international technology market. It has important realistic significance on China's tax legislation and bilateral taxation agreement negotiation, and also has a good reference value to broad activists and management personnel engaging in technology import & export practice.The dissertation consists of four parts, and the main contents of each part are as the follows:Chapter one describes issues of income tax related to technology import, it mainly bases on technology import trading business, and analyses income tax paying status both in China and countries technologies exported by analysis of jurisdiction to tax and calculation mode.Chapter two briefly addresses international double taxation and avoiding double taxation measures, while emphasizes on avoiding double income taxation in technology import basing on the concerned content of taxation agreements between China and the related countries.Chapter three addresses tax sparing credit. It combines taxation preferential policy and tax sparing credit, analyses the impact of tax sparing credit on taxation preferential realization on the basis of the agreed tax sparing credit content in taxation agreements between China and the concerned countries. Meanwhile, it set forth Net Price (without Chinese tax) terms in technology license practices, and points out its unsuitableness in such situation.Chapter four,based on the analysis of the previous chapters, puts forward suggestions on the following three respects:1. Make further consultation on international taxation to avoid double taxation on license fee for technology in unification in world-wide and boost the application of the technologies globally.2. Chinese government further consults with the concerned countries on income tax like technology license fee and etc. to promote import of offshore new hi-tech into China.3. Improve Chinese income tax policies on technology license fee to promote Chinese technology enter into the international technical market.