Research On The Taxation Of Royalties In Bilateral Tax Tyeaties

Bilateral tax is the most important and main legal basis of our various tax income in the transnational transactions of intangible assets.But even if so,the royalty also does not have the method namely to determine to have the general affirmation and the stipulation.This has become a great obstacle for us to implement,reduce,reduce and even eliminate double taxation under the guarantee of fairness.In the same way,this also gives us a bad impression on the investment of transnational intangible assets related to foreign affairs.Because the royalty is identified in the process of generation,there are many different ways of transaction,the form is different.We should start with different forms and modes to find a representative point of view,and from this point of view to explore and observe the problem of tax identification of royalties.But in the observation and exploration at the same time,we should also pay attention to the substantive grasp of the transaction,pay attention to the transaction process of the actual identification is far more important than the formal identification.This identification path requires us to sort out the relationship between the various powers and abilities that appear and occur in the transaction process,and improve,think about,and put forward feasible suggestions.Nowadays,our country’s tax collection and management system has made a lot of improvement,but we still need to make progress compared with those developed countries.There are still a lot of questions about the identification and use of royalties in our country.For example,the relevant laws and regulations are not detailed enough,the system provisions are not specific enough,and the overall problem has some blank spots and so on.This makes our country in the tax fees,tax subjects and other aspects are vague and difficult to identify,resulting in our government work is difficult to carry out.From this point of view,in order to let our country in the international achieve higher achievements,obtain a higher status,and in the international economic exchanges,reduce the problem of conflict,royalty research and improvement is very necessary.However,in the process of actual tax development,royalties are different from ordinary tax collection,no matter in the aspects of identification,subject,or jurisdiction of various countries,there are differences.This will cause some related problems to be solved,so that the collection and management of royalties are difficult to carry out smoothly.Royalty itself is different from other tax expenses,it has certain ambiguity and uncertainty,that is,it is difficult to identify and distinguish.This creates a lot of problems and risks.With the rapid development of economy and technology,new forms of business and new industries are constantly emerging,and the transaction costs of new market entities are constantly updated.The tax costs of these new forms of business and new industries make it more difficult to identify and classify the royalties.In addition,China’s relevant tax laws and regulations are relatively backward,which makes China face more difficulties and challenges on the tax issues in this aspect.Our country should keep up with the trend of The Times,vigorously develop emerging industries and technologies,and absorb the current international excellent experience and advanced relevant tax systems and regulations.International tax related institutions in our country has certain defects and omissions,in order to better service the tax main body,to be fair to deal with the international economic bilateral tax problems,millions of people of insight to contribute quite a lot of experience and research,the author also based on these excellent views and research meager opinions are put forward.