区域贸易安排与所得税差别待遇的消除:现行机制与未来路径

Regional Trade Arrangements and Elimination of Differential Income Tax Treatment:Current Mechanism and Future Path

WTO多边贸易体制和区域贸易安排并不干涉其成员的所得税制度。然而,各国的歧视性所得税措施和正常税制所导致的差别待遇还是会对国际贸易和投资产生壁垒效应和扭曲作用。对于构成贸易壁垒的所得税歧视措施,区域贸易安排沿用WTO的非歧视原则来进行规制;对于各国所得税制所导致的差别待遇,区域贸易安排则借助国际税收协定来处理。不过,WTO的非歧视原则和国际税收协定的现行机制并不能彻底消除所得税差别待遇,多边贸易体制和国际税收协定都有进一步完善的空间。对于追求更高自由化水平的区域贸易安排来讲,可尝试其它新的机制。

The WTO regime and regional trade arrangements do not interfere with the income tax systems of their members.Discriminatory income tax measures and differential income tax treatment caused by the normal income tax systems of the members of regional trade arrangements do have distortive effects on international trade and investments.Regional trade arrangements coin the non-discrimination principles of the WTO regime to deal with discriminatory income tax measures which in fact are trade barriers,and take the advantage of double taxation conventions to deal with differential income tax treatment caused by income tax systems of their members.However,the WTO regime and the double taxation convention can't thoroughly eliminate discriminatory income tax measures and differential income tax treatments.The members of regional trade arrangements,with the view to achieving further liberalization,should refine the trade regime and double taxation convention and try to design new mechanisms.