The Legal Issues Of Tax Coordination Between China And Foreign Countries Under The Background Of "The Belt And Road"

At present,"the the Silk Road Economic Belt and the 21st-Century Maritime Silk Road" as China's national top-level development plan is of great significance for further improving China's opening up pattern,tapping regional economic development momentum,and building a fair and just new international order.As an initiative country of "the Belt and Road",China should play an exemplary role in the construction of "the Belt and Road" system.In the international taxation field,along with the development of economic globalization,"the Belt and Road" is facing a new international tax environment.The diversification of tax sources,the growing erosion of tax base erosion and profit transfer,and the increasingly fierce competition among countries for tax sovereignty pose new challenges to "the Belt and Road" international tax coordination.In this regard,China should attach great importance to exploring the Chinese and foreign tax coordination mechanisms that meet the development needs of "the Belt and Road".Through the introduction and the five chapters of the text,this article studies the legal issues of tax coordination between China and countries along "the Belt and Road".The first chapter of the main body of the text serves as the starting point of the full text.It begins with "the Belt and Road" initiative,summarizes the process of "the Belt and Road" initiative,analyzes the characteristics and positive significance of "the Belt and Road" initiative,and points out the international taxation facing "the Belt and Road"initiative.Secondly,in view of international tax coordination,the connotation and influencing factors of national tax coordination were introduced,and the positive effect of international tax coordination on "the Belt and Road" was pointed out.Finally,it elaborates on the requirements and challenges of "the Belt and Road" tax coordination between China and foreign countries,and then leads to the discussion of corresponding legal issues in Chapters second to fourth the text.The second chapter of the text explores the legal issues of taxation system coordination between China and foreign countries.Based on the necessity and the existing efforts of "the Belt and Road" Chinese and foreign taxation system,it specifically analyzes the relevant content of the Sino-foreign double taxation agreement.Furthermore,the issue of "the Belt and Road" coordination between Chinese and foreign taxation systems also has the following problems:the internal tax system does not adapt to international development trends,the content ofdouble taxation agreements is lagging behind,and the tax system coordination network is not comprehensive.The third chapter of the text discusses the legal issues of anti-avoidance coordination between China and foreign countries.Based on the necessity and the existing efforts of "the Belt and Road" anti-avoidance coordination between China and other countries,the specific analysis of anti-tax avoidance coordination measures "the benefit owner" system,the main purpose testing rules and the dual-resident clause,and then proposed anti-avoidance coordination between China and foreign countries has the problems:"the beneficial owner" system is not perfect,the domestic anti-avoidance tax legislation is too low,and the new anti-tax avoidance coordination measures have yet to be implemented.The fourth chapter of the text discusses the legal issues of tax information exchange between China and foreign countries.Based on the necessity and the existing efforts of"the Belt and Road" exchange of tax information between China and foreign countries,it specifically analyzes the law of exchange of tax information between China and foreign countries,the "The Multilateral Convention on Mutual Administrative Assistance in Tax Matters" and "Multilateral Competent Authority Agreement on Automatic Exchange of Financial Account Information".Then,it is proposed that exchange mechanism for the exchange of bilateral tax information between the Chinese and foreign tax information exchange systems still has an object of tax information exchange being unclear,and the system of multilateral tax information exchange needs to be developed,and the tax counterparty is not informed of the procedure.The fifth chapter of the text proposes corresponding suggestions for strengthening tax coordination mechanism between Chinese and foreign countries in response to the specific problems found in Chapters two through four of the text.In strengthening the coordination of Chinese and foreign taxation system,it is proposed that the reform of the domestic tax legal system,the renewal of the double taxation agreement and the improvement of "the Belt and Road" the tax system coordination network should be strengthened.In strengthening anti-avoidance coordination between China and foreign countries,it is supposed to enhancing the operability of the "beneficial owner" system,and the legislative hierarchy of anti-avoidance rules should be improved,the implementation of newanti-tax avoidance measures should be actively promoted.In terms of improvement of China-Foreign tax information exchange system,it is proposed that the object of tax information exchange should be clarified,the system of multilateral tax information exchange should be improved,and the protection of transnational taxpayers should be strengthened.