By Studying The Current Situation Of Income Taxation On On-residents

With the development of globalization of economy, the interactions betweenenterprises are more and more frequent and many enterprises engaged into differentinternational investment in different forms, involving in the division of worldwidemanufactures, which at the same time imposes impact to the international taxationsystems, with the economic model of cross board movement of products turning intocross board movement of capital in international society. More and more investorschoose to make investment in the countries or regions which have certain advantages,which results in economic behaviors of cross board investment. Such enterprises andindividuals not only have gains or properties within the territory of the country theydwell on, but also different income from and property invested in other countries. As theincome and properties of enterprises and individuals become more and more commonand develop fast, so the international taxation and the relations are becoming necessary.As the fast development of economy, a lot of non-residents have incomes fromcross-board investment, which leads to disputes of jurisdiction and interests of taxationbetween countries, and disputes of economic interests between countries andbusinessmen. The disputes of double taxation, avoidance and evasion of tax are resultsfrom the fact that the governments excise their taxation power in their sovereigntyterritories.The essay consists of four parts, by studying the current situation of incometaxation on non-residents, analyzing the economic and legal background and practical political and economical needs of non-resident system. The essay intends to proposesimprovements to Chinese national tax policies after analyzing the core question ofnon-resident income taxation-permanent establishment principle, comparing andstudying the tax treaties of different countries, drawing reference from advancedtheories and taxation systems in developed countries and puts forward thoughts andsuggestions for international economical cooperation carried out by our country andenhance taxation of income taxation on non-resident enterprises and promotesdevelopment of economy in our country.Part one is the analysis of current taxation system on non-resident enterprises andintroduction of the economical and political background of its emergence anddevelopment and elaboration of needs of political and economical needs internationallyand domestically.Part two is the theoretical analysis on relevant income taxation on non-residententerprises and definition of non-resident enterprises. This part, after taking reference tothe commentaries of OECD tax convention and UN tax convention and internationaleconomical books, make categorization of profits of non-resident enterprises andpermanent establishments which are two important issues of non-resident taxations.Part three makes a comparison of non-resident profit and permanent establishmentin international model tax convention and introduces taxation system of non-residenttaxation in America, Britain, Spain and Japan.The fourth Part comes up with suggestions to the international economicalinteractions and improvement of taxations after analyzing the taxation system in ourcountry and analyzing non-resident taxation system beforehand.