| With the promotion of economic globalization,the openness and inclusiveness of China's economy have continued to expand.The flow of international capital climbed.In 2014,China surpassed the world's largest economy for the first time—the United States and thus became the largest FDI inflow country.Multinational corporations have entered China in various forms such as the establishment of joint ventures,sole proprietorships,and branch offices.Cross-border transactions have been complicated.The borderless flow of income tax sources and the national border jurisdiction of tax jurisdictions have caused serious problems between tax authorities and taxpayers.Information asymmetry,which caused great losses to cross-border tax sources in various countries.Since the financial crisis of 2008,major economies such as the European Union and the United States have started to actively implement the practice of tax information exchange for taxpayers,and international tax information exchange has begun to enter an all-round development stageThe role of international tax information exchange in economic activities has become more and more significant.The form and content of information exchange has also been continuously extended in depth and breadth.The establishment and improvement of the international information exchange system laws and regulations has also become a problem that China urgently needs to solve.In the face of increasing harmful tax revenues,the Internal Revenue Service of the United States has continued to explore the establishment of international tax transparency and has taken the lead in introducing the FATCA.At the same time,the OECD has also revised the "Multilateral Convention on Mutual Legal Assistance in Tax Collection and Management" in accordance with the needs of the international situation and issued the "Financial Account Information Automatic Exchange Standard" on taxation,which provides specific guidelines for the automatic exchange of tax information.Faced with the rapid development of tax information exchange,the main pointsof this paper are: First,how to more effectively respond to the traditional request for information exchange.Second,in the face of the soon-to-be-implemented automatic exchange of taxation information,how should it be determined at this stage based on a full and clear understanding of national interests,which specific countries should exchange information,and actively respond to the automatic exchange between FATCA and taxation information in the United States? Match points are different.Revise China's relevant laws and regulations,earnestly perform its obligations under the "Convention" and the agreement,and enable the transition period between the traditional information exchange and the automatic information exchange to be stable,and on the premise of actively safeguarding national taxation rights and interests.Encouraging taxpayers to obtain “forgiveness” through voluntary disclosure also provides new ideas for tax authorities to deal with issues left over from history,and fully protects the legitimate taxation rights of taxpayers abroad.This article first elaborated the research background and significance of the international intelligence exchange work,systematically introduced the relevant theories and development history of international tax information exchange,and the working mechanism and development status of the automatic exchange of tax information that the OECD is currently advancing.The status quo of automatic exchange of information has been sorted out.Through the investigation of OECD and other countries' initiatives and viewpoints,and in conjunction with the investigation of the Starbucks tax avoidance case in the EU,the application of tax information exchange is discussed.We will thoroughly analyze the problems China faces in the exchange of information in the hope of providing reference value for the construction and management of tax information exchange systems in China. |
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