Research On The Legal Issue Of Bilateral Tax Agreements Under The "Belt And Road" Initiative

As an important norm for coordinating taxation among various countries,international bilateral tax treaties have an indispensable role in eliminating double taxation,cross-border tax disputes and tax evasion,and solving the tax problems of countries along the "Belt and Road"and China.It also has a very important position.However,it is worth noting that China's economic development imbalances,historical and cultural differences,and political environment stability are very different,so when faced with complex and volatile tax issues,bilateral taxation The role of the agreement is also limited,and it is difficult to adapt to the new tax problems emerging in the current complex and volatile investment environment.Therefore,how to break through the legal limitations of the previous tax treaties to solve the current problems to adapt to the new situation of the development of China and the countries along the line to It is important.Under this background,the article analyzes and analyzes the bilateral tax treaties that China and the countries along the line have signed under the "Belt and Road" strategy.The first part is to introduce the historical lineage and reality of bilateral tax treaties between China and countries along the route.On this basis,the main provisions of the bilateral taxation agreement,such as the double taxation method clause,the non-discrimination treatment clause,the negotiation procedure clause and the information exchange clause,are summarized.Secondly,based on the study of its content and role,Find out the flaws and shortcomings in the existing tax treaties,and set the criteria for determining the resident identification status of the "Belt and Road"partnerships and setting up the "Belt and Road" cross-border virtual permanent establishments based on the specific conditions of China and the countries along the route.And the introduction of the "Belt and Road" compulsory arbitration clause to resolve tax disputes,including targeted and practical recommendations.Finally,we will turn the research perspective into the future economic development trend,and combine the characteristics of China and the countries along the "Belt and Road" strategy,and conceive the development ideas of the tax treaty under the "Belt and Road" strategy,including learning from the Sino-US and Sino-French tax treaties.Successful tax treaty practices such as EU tax cooperation and the integration of the latest international taxation results into bilateral tax treaties under the "Belt and Road" strategy in the context of the BEPS Multilateral Convention and CRS.Under this circumstance,not only can we better solve the tax problem between China and the countries along the line,but also promote the better and more sustainable development of the "Belt and Road" strategy,and enable our country to accumulate experience in signing and amending international tax treaties.Other countries provide reference for promoting the bilateral tax treaty between China and the countries along the "Belt and Road" to move toward a farther and greater goal.