Research On Taxation Issues For Cross-border E-commerce Transactions

With the progress of economic globalization and information technology,the cross-border e-commerce transactions has become one of the important form of international trade in our country.It not only brings a big change in business model,but also causes a huge impact on the collection and administration of the tax law system which are based on the traditional mode trading system in China.In this paper,based on China’s cross-border e-commerce transactions tax legislation and the status quo of the collection and administration,the current cross-border e-commerce transaction tax theory overview and collection and management system are analyzed.On this basis,the Apple tax case,for example,analyzes the multinational companies in cross-border e-commerce transactions tax commonly used gimmick and damage to the related countries,as well as the relevant countries to save for multinational tax avoidance tax anti-avoidance of adjustments.Apple used its global holding structure as well as a global sales network,using the the loophole of relevant countries and collection of the tax law,taking use of Luxembourg tax avoidance harbor for digital product tax avoidance,tax avoidance by means of subsidiary double the tax resident identity based on cost allocation protocol cross-border transfer pricing,and the use of multiple measures to evade CFC \ "tick\" rules such as means to evade tax obligations,caused tax loss to the EU member states.To deal with these tax avoidance of Apple,the European Union added levies on cross-border e-commerce products trading rules,perfecting the tax regulation of double the tax resident identity,the European Union’s tax directive(ATAD),further strengthening cross-border electricity trade within the EU regulatory measures such as tax,carried on the anti-tax avoidance to tax avoidance of Apple.These regulations and measures of our country have a very good reference.Combining with China’s cross-border e-commerce transactions and the present situation of tax legislation,in further reference to the United States,the European Union,Japan,the OECD and other related tax collection and management system and based on the analysis,proposed some suggestions of consummating our country cross-border e-commerce transactions tax collection and management measures,such as perfecting for digital product cross-border trading revenue management policy,perfecting our country about double the tax resident tax regulations,and further refining the controlled foreign companies in our country the relevant tax provisions,to strengthen the international tax havens of involved in cross-border trade in our country’s tax management,consummating our country cross-border electricity transaction cost allocation protocol and pricing method,modifying booking special tax adjustment measures for implementation,further strengthening the management of general anti-avoidance,actively participating in international cooperation and CRS action,strengthening the tax information exchange.Implementing appropriate for cross-border e-commerce transaction preferential tax policies,etc.Cross-border e-commerce transactions is a new form of trade,the relevant tax policy and collection system is still in the process of improving.Multinational firms take advantage of the loopholes in tax collection and management,and this behavior of tax avoidance will exist for a long time.And our government’s efforts to reverse tax avoidance will continue.I am looking forward to the further exploration in that direction in the future.