Research On International Tax Law Of Collective Investment Instrument

Collective Investment Vehicles, is a kind of widely used indirect investment tool. As a financial innovation, collective investment vehicles to achieve the balance between risk and return, which is a kind of effective collective investment and risk management tool. Collective investment vehicles is a variety of investment tools, that not only can provide more investment opportunities for investors, but also conducive to solve the financing problems of China’s enterprises.This paper attempts to introduce the clarify concept of collective investment vehicles, characteristics and classification of collective investment tool. And on the basis of tax issues involved in the operation process of collective investment vehicles, especially the study of international tax issues.The first chapter of this paper mainly introduces the basic concept, characteristic, classification of collective investment vehicles and mode of operation, which mainly with the professional knowledge of finance to clarify the concept and classification of collective investment tool, and analyzes the main taxes involved in collective investment vehicles during operation. The research of collective investment vehicles is mainly concentrated in the narrow sense of collective investment vehicles, and the related tax restrictions in the tax area.In the second chapter, the third chapter and the fourth chapter discusses the legal problems of international tax collection of investment vehicles, investment income tax should follow the principle of collective investment vehicles, the distribution of profits taxpayers are investors or collective investment vehicles itself, set the qualitative and profit distribution investment profit distribution to avoid double taxation and the problem collective investment vehicles in international taxation management etc. On international tax collection of investment tools involved mainly with reference to the relevant report and OECD Model Tax Convention and notes.The last chapter of this thesis analyzes the tax problems of collective investment vehicles in our country development, mainly review the existing collective investment vehicles and related securities investment tax laws and regulations, as well as the bilateral tax agreement signed between China and other countries between the collective investment tool has closed and the terms of the. The legislative proposals for the development of collective investment vehicles industry in China, and how to join the relevant clause in bilateral tax treaties.