国际税收双语-Chapter-1-Bases-for-International-Tax课件.pptx

1、主讲人：葛夕良浙江财经大学What is “International Tax”?Relationship between“InternationalTax”and“Jurisdiction Taxations”ACWhat is“Jurisdiction Taxations”?Taxations in the USA and IrelandBDChapter 1International Tax and Bases for International Tax:Jurisdiction TaxationsA.What is “International Tax”?nA well-known s

2、aying in English is that two things cannot be avoidedin life:death and tax.nInternational Tax is part of Modern Tax as well as Public Finance.Therefore we can say here International Tax is inevitable in modernlife with growing globalization.nWhat is International Tax,then?InternationalTaxThe term In

3、ternational Tax may be considered a misnomer.What we refer tohere for convenience as international tax laws is more correctly referred to asthe international aspects of the income tax laws of particular countries.(from a textbook named International Tax Primer)A1:Brian J.Arnolds viewpoint:Internatio

4、nalTax“Misnomer”means incorrect usage of a name.Because no governmentexceeding a national government such as UN or OECD or EU levies taxes.Thus actually no international tax exists in the world.International Tax actually means“international tax laws”or in a narrowsense,the international or foreign-r

5、elated aspects of the income tax lawsof particular countries.How to understand the viewpoint?InternationalTax International Tax is a science on tax distribution among sovereigntycountries.It results from cross-border direct investments made by multi-national taxpayers and direct taxes designed by va

6、rious countries.A2 :Viewpoint from a textbook in ChinaInternationalTaxThe definition is not absolutely correct.Reason 1:International Tax covers not only direct taxes but also indirecttaxes.Reason 2:It results from both direct investments and indirect investments.Reason 3:International Tax is a tax

7、distribution among sovereignty countriesand special territories such as Hongkong,Cayman Irlands,etc.My Comments:InternationalTaxInternational Tax is a subject focusing on a series of common foreign-related tax issues such as Tax Jurisdiction,International Double Taxationand relief,International Tax

8、Treaty,International Tax Avoidance and Anti-avoidance Rules,International Tax Competition and Harmonization,etc.resulting from different and conflicting international tax systems or rulesdesigned by particular sovereignty countries or highly autonomousjurisdictions,and their resolutions or counterme

9、asures.A3 :my viewpoint:InternationalTax International Tax in a broad sense covers all types of taxes such as commoditytaxes or turnover taxes,income taxes,property taxes and minor taxes as well.Thats to say,both direct taxes and indirect taxes.International Tax in a narrow sense involves only incom

10、e taxes and propertytaxes or so-called“direct taxes”.Sometimes from one countrys perspective,International Tax means foreign-related taxation of a country or territory taxation.A3 :my viewpoint:InternationalTax B1:“Jurisdiction”here means a country.Singapore;China Mainland;UK;USA,etc.B2:“Jurisdictio

11、n”here may also mean a special area or territorywhich has its own independent taxation rights.Hongkong,CaymanIslands,Bermuda,etc.B.What is“Jurisdiction Taxations”?InternationalTaxl B3:“Jurisdiction Taxations”refers to tax systems in different countries and special territories.l China Taxationl UK Ta

12、xationl USA Taxationl Hong Kong Taxationl Bermuda Taxationl Cayman Islands Taxationl .l Different countries and territories,different taxations.They are bases for us to study International Tax.What is“Jurisdiction Taxations”?主讲人：葛夕良浙江财经大学主讲人：葛夕良浙江财经大学What is “International Tax”?Relationship between“

13、InternationalTax”and“Jurisdiction Taxation”ACWhat is“Jurisdiction Taxation”?Taxations in the USA and IrelandBDChapter 1International Tax and Bases for International Tax:Jurisdiction TaxationInternationalTaxInternational Tax3C.Relationship between International Taxand Jurisdiction Taxation C1:Interna

14、tional Tax is based on Jurisdiction TaxationWithout Jurisdiction Taxation,without International Tax.Therefore,to learn International Tax well,one has to know a lot about JurisdictionTaxation.At least he has to know about some typical countries and territoriesFor us Chinese,we have to learn China Tax

15、ation before learning International Tax.The title means international tax rules or events may affect a jurisdictionsunilateral tax rules.For example:The USAs Trump Tax Reform in 2018 is a great international tax event in thefield of International Tax.It reduced the Federal corporate income tax ratef

16、rom 35%to a flat rate of 21%,thus resulting in a new round of InternationalIncome Tax Competition in the world.What shall we do in such background?Shall We reduce our Enterprise Income Tax rate from 25%to 20%?InternationalTaxC2:International Tax has important effects onJurisdiction TaxationInternati

17、onalTax As we know,our domestic final dividend withholding tax rate is 10%.So if a Chinese resident corporation pays 1 million to a company in Singapore.We can impose 10%of dividend withholding tax,thats to say,100000 income tax.But by international tax treaty between China and Singapore,the Singapo

18、recompany has only to pay 5%of 1 million or 50000,if requirements are satisfied.Here the international tax treaty rule affects the unilateral tax rule.So aninternational taxpayer has to study International Tax to his own advantage.InternationalTax D1 Taxation in the UnitedStatesD.Jurisdiction Taxati

19、onInternationalTax United States of America is a federal country with an area similar to our country anda population of 327 million.USA has a taxation system which is quite different from that in our country.The Federal government has Personal Income Tax,Payroll Taxes and CorporateIncome Tax as her

20、main taxes.Minor taxes are Estate Tax and Gift Tax,Excise Tax,Stamp Duties,Customs Duties,etc.Taxation in brief in the USAInternationalTax The State governments have their own seperate taxes.Generally,Sales Tax,Personal Income Tax,CorporateIncome Tax,Property Taxes are main taxes.Minor taxesare Esta

21、te Tax and Gift Tax,Excise Tax,etc.In California,State Sales Tax,State Personal IncomeTax and State Corporate Income Tax,Property Taxes,Excise Tax,etc.The Local governments:Property Taxes,etc.InternationalTaxTax Revenue Structure for USA Federal GovernmentInternationalTax2.1 Taxes on Income,sales,an

22、d property in States2.2 City and county taxes=local taxes2.State and local government taxation in USAInternationalTax Alabama:Florida:Hawaii:Texas:Alaska52;51;51;50;20;12;15;17;37;61;21;23;26;0;0;151161319 New Hampshire 19;66;1;14 New Jersey:27;46;18;9Tax percentages in different States of the USASa

23、les tax;Property tax;Income tax;Other revenuesInternationalTax As for local taxes in the USA,Lets take for example County of Prince in the state of California.InternationalTaxInternationalTaxTaxation in the Republic of IrelandInternationalTax Ireland is a country with a small area of around 70,273 s

24、quare kilometers and a little population of around 4.8 million.Simple Taxation.All taxes are collected by IRS(Top tax authority)and all revenues are remitted to Centralgovernment which decide how to use them.At present,percentages of different taxes are(Personal)Income Tax(41.4%)、VAT(27.8%)、Excise T

25、ax(12.8%)、Corporation Tax(11.5%)and Stamp duties(3.9%),etc.Taxation in brief in the Ireland(Chinese)Ireland has other minor taxes:Capital Acquisitions Tax,Capital Gains Tax、Deposit Interest Retention Tax、Dividend Withholding Tax、DomicileLevy、Environmental Levy,Local Property Tax,Professional Service

26、sWithholding Tax,Relevant Contracts Tax、Tonnage Tax,Universal SocialCharge）、Vehicle Registration Tax,etc.1.What is international tax?What does it mainly address?2.Talk about differences between China and USA on taxation system 3.On differences among Macau,China Mainland and Hong Kong forthe purpose

27、of tax features according to Table 1E.Questions for further consideration in Chapter 1InternationalTax 4.On differences among UK,China Mainland and Spain for the purpose ofCorporate income tax according to Table 2 5.On differences among China Mainland and foreign jurisdictions for thepurpose of withholding taxes according to Table 3 6.Please write at least 3 differences between USA and Ireland on taxationQuestions for further consideration(continued)主讲人：葛夕良浙江财经大学