海峡两岸所得税制度差异对消除两岸重复课税的影响

On the Differences between Income Tax Systems of the Continent and Taiwan and Their Effects on Eliminating Double Taxation between Two Shores of Taiwan Straits

大陆与台湾所得税制在有关纳税人的居民身份确认和所得来源地认定标准、所得税税基确定、税收征管方式以及境外所得税抵免等方面,彼此的规定存在差异。这些差异在一定程度和范围影响到两岸各自单边规定的境外所得税抵免制度适用于消除两岸所得重复课税的实际效果。准确地认识两岸税制间的这些差异和不同,有助于两岸在将来可能进行的税收协调安排中采取有效的协调措施解决问题。

With respect of the standards for identifying the status of resident taxpayers and the source of income, the determination of income tax base and the credit of foreign income tax, there exist differences between the income tax laws of the Continent and Taiwan. These variances and differences of the income tax systems may, to some extent, influence the actual effectiveness of eliminating double taxation between two shores of Taiwan Straits when the foreign tax credit rules provided respectively in the income tax laws of the Continent and Taiwan are applied to eliminate double taxation between two shores of Taiwan Straits. Identifying these variances and differences of the income tax systems of the Continent and Taiwan will be helpful for relevant authorities of the Continent and Taiwan to take effective measures to solve the issues through possible taxation reconciliation between the two shores of Taiwan Straits in the near future.