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A Legal Study On The Taxation Of Cross-Border Royalties In The Context Of Tax Treaties

Posted on:2014-06-10Degree:MasterType:Thesis
Country:ChinaCandidate:Y F PeiFull Text:PDF
GTID:2256330425959227Subject:International Law
Abstract/Summary:PDF Full Text Request
Since the end of last century and the beginning of this century, a lot of revolutions happened, of which the most far-reaching impact on human society is the information technology revolution. Economic research data shows that, the proportion of the international technology transfer of cross-border trade volume is rapidly increasing in the21st century. The number of intangible product trading, such like intellectual property rights trading, has been far more huge than in the traditional economic times. However, intangible product trading contains great possibility of cross-border royalties.Therefore, it is essential to research and reform the tax system of royalty. Besides, it is also important to research how to coordinate domestic tax law and international tax model agreement in practice. A series of cross-border technology transfer is coming accompanied by the continuous development of the cross-border trade. However, there are still lots of controversy need to be resolved on the qualitative and attribution of the right to tax. Theoretical analysis is finally ordered to solve practical problems. Therefore, it is necessary to sum up the concrete practice way on the basis of the theoretical analysis of these two issues, of which the differences between the way of practice at home and abroad is the focal point. This article finally reaches the conclusion on basis of all the discussions above. And the conclusion is that it is imperative to reform the domestic law of tax and the way we explain regular rules.In summary, the study of this problem would provide guiding principles and operation of the program system of royalty, and to promote the prosperity and sustainable development of our technology import and export trade. Meanwhile it is benefit for promoting the development of our international income tax system, protecting the tax financial interests of our country and preserving the exercised of our tax sovereignty.
Keywords/Search Tags:cross-border technology transfer, tax treaty, cross-borderroyalties, right to tax
PDF Full Text Request
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