Study Of The Legal System Of Foreign Tax Credits

Foreign tax credit legal system is an important institution of international tax law .It is also an important method accepted widly by international society to resolve the international double taxation .This dissertation discusses the essential theory of foreign tax credit legal system , including the superiority of foreign tax credit in resolving international double taxation ,a classification and a comparative study on foreign tax credit ,and also discusses some problems in the applying process of foreign tax credit legal system ,including the qualifications and limitations on foreign tax credit with expatiating the author's opinions After referring the perfect experience and theory of developed countries, this dissertation also discusses how to improve the foreign tax credit legal system of our country. The dissertation is consisted of five parts, besides an introduction and a conclusion.The first part is a study of international double taxation .This part studies on the concept of international double taxation that the foreign tax credit legal system is going to resolve And there is a comparative study about the methods of resolving international double taxation and the study emphasizes on the superiority of foreign tax credit.The second part is a classification and a comparative study on foreign tax credit .This part studies on direct credit and indirect credit legal system ,full credit and ordinary credit legal system ,and also studies on international tax sparing credit legal system ,involving the concept , feature, applied area of all above ,and a comparative study about them.The third part discusses qualifications of foreign tax credit .The qualifications involve three facets ,the qualifications of taxpayers ,of foreign taxes and of procedures. The law provides these qualifications for foreign tax credit for the aim of maintaining the foreign tax credit is just to be used to avoid international double taxation .But this aim can not always be achieved .This part also discusses particularly qualifications of indirect foreign tax credit, relationship of indirect foreign tax credit and avoiding international double taxation.The fourth part discusses limitations on foreign tax credit .This part studies on...