我国与“一带一路”沿线国家合作型国际税收治理

CooperativeInternational Tax Governance between China and Countries along“The Belt and Road”

自“一带一路”倡议提出以来,随着“五通”政策继续推进,广泛的国际合作共识已形成。中国与沿线国家的经贸往来更加深入密切,涉税情况以及规模、复杂程度都远超过去。传统税收协定争议解决机制存在协商拖延、争议难决等挑战,数字经济税合理性还存在争议,国际税收关系也成为“一带一路”沿线国家共同的治理要求。从实践层面看,继续完善MAP机制协商解决税收争议仍然是“一带一路”沿线国家奉行的税收治理方式,中国作为发起倡议国,不仅应积极与沿线国家签订、修订税收协定,避免增加国家税收争议,降低企业税收负担,还需要平行调整国内税收规制,加强多边税收合作。

Since the undertaking of“the Belt and Road Initiative”,the consensus of international cooperation has been formed along with the“five focuses”policy.The economic and trade exchanges between China and the countries along the belt and road are more in-depth and closer,and the tax related situation,scale and complexity are far higher than in the past.The traditional dispute settlement mechanism for tax treaties faces challenges such as delayed negotiation and difficult dispute resolution,while the rationality of digital economy tax is still controversial.International tax relations become common governance requirement in the countries within Belt and Road have common governance requirements.From a practical perspective,continuing to improve the MAP mechanism to negotiate and resolve tax disputes is still the tax governance method pursued by countries along the Belt and Road.As a sponsoring country,China should not only actively sign and amend tax treaties with countries along the route to avoid increasing national tax disputes and reduce corporate tax burdens,but also need to adjust domestic tax regulations in parallel and strengthen multilateral tax cooperation.