A Comment On The Cross-strait Taxation Agreement

In August 2015,the mainland and Taiwan signed the" to avoid double taxation and strengthen tax cooperation agreement in Cross-strait"(referred to as "cross-strait tax agreement"),which is the first signed comprehensive bilateral tax treaty,achieving a new breakthrough in the tax field."Mainland and Hong Kong Special Administrative Region on the Avoidance of Double Taxation and Prevention of Fiscal Evasion",the main signed body of the relationship between the two sides,the content of the text has a greater similarity,which is the two agreements are linked to each other.At the same time,there are more differences between the two agreements,such as the difference between the provisions of the actual management agency,the duration of the permanent establishment of the project,they explain the mainland and Taiwan,Hong Kong's different processes.By exploring the causes of the differences,such as the different tax systems of the three places,the development of economic and legal environment at different stages can not only guide the revision of the Taiwan Income Tax Law,but also provide experience to the future "cross-strait tax agreement"for reference.This paper is divided into three parts:The first part is aiming at the birth background,benefits,comparable basis made a comprehensive introduction,and then the second part is aiming at differences between the two For the sake of detailed comparison and exploring the reasons,the final part is explaining the two agreements are both linked and different,the reasons for the differences may affect the two sides Tax policy,and pointed out that the "cross-strait tax agreement" still has shortcomings,it can learn from the "Hong Kong tax arrangements" revised experience.The innovation of this paper lies first in the innovation of the topic.This paper chooses the "Hong Kong tax arrangement" as the object of comparison,by comparing the "cross-strait tax agreement" innovation,this research perspective in the country is more novel.The second is that the research on the perspective of innovation,such as the "cross-strait tax agreement" in the text system,cross-strait tax links and business systems,"four principles" of information exchange and other aspects of a completely different from the conventional tax treaty,the taxation of property income tax,etc.to provide more favorable tax treatment than the "Hong Kong tax arrangements".