国际税收整理.doc

课后习题整理
Base for international tax: country taxation
What is international tax? What does it mainly address?
答:International tax means a series of tax issues resulting of different tax rules and conflicting jurisdictions made by countries, and solutions.
International tax in a board sense covers not only e taxes but also turnover taxes, etc.
International e taxation
How does a country generally design its e taxation system?
答:①territorial(属地): taxation only of in-country e,. Hong Kong;
②residency(属人): taxation of all e of residents and/or citizens;
③exclusionary(例外): specific inclusion or exclusion of certain amounts, classes, or items of e in/from the base of taxation;
④Hybrid(混合): . USA , UK
Why is it important to make clear source of e?
答:①in a territorial system, source often determines whether or not the e is taxed; ②source of e is also important in residency systems that grant crs for taxes of other jurisdictions.
Tax residence
What is the main difference between a tax resident and a non-tax resident for tax liability purpose?
答:①a tax resident: world-wide tax liability;
②a non-tax resident: limited tax liability.
Can you name some tests in determining whether a person is a resident?
答:①For corporation:
place-of-incorporation test , place-of-management test,
residence-of-the shareholders test;
②For individual:
a fact-and-circumstances test/ domicile test ,
number of days test, intention test.
Take an example to prove how different countries apply differing tests to judge a person's residence?
答:China: for individual: domicile test , number of days test(a full year);
for corporation: place-of-incorporation test
or place-of-management test.
Ireland: for individual: number of days test(183 days) ,domicile test
for corporation: now :place-of-incorporation test
past :place-of-management test.
e source jurisdiction and rules
What is source jurisdiction?
答:It's an important form of state tax sovereignty. It d