全球化视野下中国税收条约政策的调适

The Adjustment of China's Tax Treaty Policy in the View of Globalization

分配税收利益与协调税务行政合作是税收条约的两个主要功能,其相关内容的变化与侧重都决定着税收条约的调整与发展。近年来,随着对外贸资本输入输出比重以及对外贸易结构发生变化,中国税收条约呈现出税收管辖权重新划分、税务合作程度与反避税力度加强两大特征。

The distribution of tax benefits and the coordination of tax administrative cooperation are two main functions of tax treaties, therefore, changes and emphasis of their relevant contents lead the adjustment and the development of tax treaties. Recently, China＇s tax treaties show two characteristics, re-dividing the tax jurisdictions and strengthening tax cooperation and anti-tax avoidance, which mark the development and the overall trend of the tax treaty policy, i.e., tax position changing from the country of origin to the country of residence and strengthening the treaties＇ function of preventing tax avoidance and evasion.