对跨国独立劳务所得认定的探讨

An Exploration on the Identification of Cross-border Independent Service Income

跨国独立劳务所得的认定在理论和实践中存在很多争议。本文结合《联合国税收协定范本》和《OECD税收协定范本》对此问题的不同规定,就我国在具体税收实践中对这一问题应如何认定进行了探讨。

There are many controversies existing on the identification of cross-border independent service income both in theory and in practice. Considering the different provisions of ＇UN Model Tax Convention＇ and ＇OECD Model Tax Convention＇ to this issue, this article makes an approach on how to identify the cross-border independent service income in Chinese tax practice.