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国际税收chapter4


Ch 4. Double Taxation Relief

Qin Luo, School of Public Finance and Taxation,SLUC

4.1 Introduction
? 1. Because most countries tax on the basis of both the residence status of the taxpayer and the source of income, foreign-source income earned by a resident of a country may be taxed by both the country of source and the country of residence. ? When tax rates are high, it’s very necessary to relieve double taxation.
Qin Luo, School of Public Finance and Taxation,SLUC

? ? ? ?

2.three types(causes) of double taxation: (1) source-source claims (2) residence-residence claims (3) residence-source claims (most popular)

? 3. Tax treaties typically provide relief from the above three major types of international double taxation.
Qin Luo, School of Public Finance and Taxation,SLUC

? 4.relief from double taxation resulting from the residence-source conflicts is ordinarily granted by the residence country. ? In other words, the source country’s right to tax has priority over the residence country’s right.

Qin Luo, School of Public Finance and Taxation,SLUC

4.2 International Double Taxation Defined
? 1. There isn’t any precise definition of the term ―double taxation‖. ? 2. legal definition of international double taxation----narrow: ? Imposition of comparable income taxes by two or more sovereign countries on the same item of income (including capital gains) of the same taxable person for the same taxable period.
Qin Luo, School of Public Finance and Taxation,SLUC

? 3. economic definition of international double taxation----broad: ? The taxable person may be different persons.

Qin Luo, School of Public Finance and Taxation,SLUC

? "Juridical double taxation" occurs where the same legal person is taxed twice on the same income or other taxable item by more than one State.
? "Economic double taxation" is where two different legal persons are taxed on the same income or other taxable item by more than one State.

Qin Luo, School of Public Finance and Taxation,SLUC

? Examples: ? (1) Jack is the resident of U.S. and he also gets service income in China in 2014. Then both US and China will tax on his service income. ? (2) T Co. is incorporated in France but has its effective management in Singapore. Then both France and Singapore will tax on the income of T Co.
Qin Luo, School of Public Finance and Taxation,SLUC

? (3) P Co. is the parent company in Japan and Q Co. is the subsidiary company in China. Q will pay the dividend to P. Obviously the dividend is from the profit after tax in China. Then the dividend of P will be taxed by Japanese government too.

Qin Luo, School of Public Finance and Taxation,SLUC

Economic Double Taxation
US Co US company liable for 10% tax on dividend income from China.

Will that potentially give rise to dividends double taxation?

China sub China Subsidiary pays 25% tax on its business income
10

? 4. If the comparable income is taxed by two different types of tax, such as sales tax and consumption tax, or income tax and wealth tax, it is not included in the double taxation discussed here. ? Can you give an example of China?

Qin Luo, School of Public Finance and Taxation,SLUC

? 5. International double taxation should be distinguished from internal or domestic double taxation. ? Domestic double taxation often happens in federalism countries.

? Eg. In U.S., the taxes include federal taxes, state taxes and local taxes.
Qin Luo, School of Public Finance and Taxation,SLUC

Customs Duty, VAT and Consumption Tax on import
Customs

Central government taxes

Offices of SAT Taxes shared between the central and local government SAT

Local government taxes

Local tax bureaus

Qin Luo, School of Public Finance and Taxation,SLUC

4.3 Relief Mechanisms
? There are three methods in common use for granting relief from international double taxation. ? Deduction method ? Exemption method ? Credit method (most difficult)

Qin Luo, School of Public Finance and Taxation,SLUC

Brief review for the steps to determine the liability of income tax
Step 1: Gross income Subtract : Exemptions and Deductions Taxable income Apply : Rate schedule Tax payable before credits Subtract: Credits Step 4: Tax liability

Step 2:

Step 3:

15

4.3.1 Deduction Method
? 1. Definition: ? Foreign taxes paid by a resident of a country are deducted as current expenses in computing the resident’s taxable income in the resident country. ? A deduction is a reduction in the gross (total) amount that must be included in the taxable base.
Qin Luo, School of Public Finance and Taxation,SLUC

? 2. Example: ? T Co. is the resident of country A.

Country A
Income Tax rate 70 40%
Qin Luo, School of Public Finance and Taxation,SLUC

Country B
30 30%

? (1) without relief of double taxation:
? Foreign tax: 30*30%=9 ? Domestic tax: 100*40%=40 ? Total tax: 9+40=49

Qin Luo, School of Public Finance and Taxation,SLUC

? (2) Deduction method
? ? ? ? Foreign tax: 30*30%=9 Foreign income taxable: 30-9=21 Total income taxable: 70+21=91 Total tax: 91*40%=36.4

Qin Luo, School of Public Finance and Taxation,SLUC

? Exercise 1:

France 290,000 35%

Germany 68,000 30%

Qin Luo, School of Public Finance and Taxation,SLUC

? 3. Valuation: ? The deduction method is the least generous method of granting relief from international double taxation, so it is not sanctioned by the OECD Model Treaty and UN Model Treaty. ? But several countries that have adopted the credit method have retained the deduction method as an optional form of relief.
Qin Luo, School of Public Finance and Taxation,SLUC

? For example, ? U.S.: deduction method and credit method ? Netherland: the foreign withholding tax can be deducted as expenses.

Qin Luo, School of Public Finance and Taxation,SLUC

? 4. Conclusion: ? The effect of the deduction method is that residents earning foreign-source income and paying foreign income taxes on that income are taxable at a higher combined tax rate than the rate applied to domestic-source income. ? So the deduction method creates a bias in favor of domestic investment over foreign investment.
Qin Luo, School of Public Finance and Taxation,SLUC

? From the viewpoint of national self-interest, deduction method may be justified. ? But from the perspective of the total tax burden on a taxpayer’s worldwide income, deduction method does not achieve equal treatment of residents.

Qin Luo, School of Public Finance and Taxation,SLUC

4.3.2 Exemption Method
? 1. Definition: ? The country of residence taxes its residents on their domestic-source income and exempts them from domestic tax on their foreign-source income.

Qin Luo, School of Public Finance and Taxation,SLUC

? 2. Application: ? (1) Very few countries — Hong Kong is a prominent example — have adopted the exemption method with respect to all foreign source income earned by their residents. (It is in fact the source jurisdiction.) ? Other examples: Panama, Argentina, Venezuela ? Q: Where does the system encourage taxpayer to invest?
Qin Luo, School of Public Finance and Taxation,SLUC

? (2) For most countries (examples: Germany, France, Spain, Holland, Austria, Norway, Sweden ) using the exemption method, however, the exemption of foreign source income is limited to certain types of income, most commonly business income and dividends from foreign affiliates. (participation
exemption,p35.p4)

? Further, the exemption method is often restricted to income that has been subject to tax or subject to a minimum rate of tax by the foreign country.
Qin Luo, School of Public Finance and Taxation,SLUC

? 3. Two methods in countries whose tax rates are progressive: ? (1) Full exemption ? (2) Exemption with progression ? An exemption method under which certain foreign-source income is exempted from tax but is taken into account in determining the rate of tax applicable to other income.
Qin Luo, School of Public Finance and Taxation,SLUC

review
? A tax rate is some percentage applied to the tax base to determine a taxpayer’s liability. ? Tax rate structure usually are either proportional or progressive. ? A proportional tax rate is one that remains at a constant percentage regardless of the size of the tax base.

Qin Luo, School of Public Finance and Taxation,SLUC

? A progressive tax rate is one in which an increasing percentage rate is applied to increasing increments of the tax base. ? A regressive tax structure is one in which a decreasing percentage rate is applied to increasing increments of the tax base.

Qin Luo, School of Public Finance and Taxation,SLUC

? Example 1: page 34 in the textbook ? Example 2: ? T Co. is the resident of country A, which adopts full progressive tax rate. Country A
Income Tax rate 70 <80, 35% >80, 40%

Country B
30 30%

Qin Luo, School of Public Finance and Taxation,SLUC

? (1) Full exemption ? The income 30 of country B is free of tax. Country A only levy tax on the domestic income 70. ? Tax: 70*35%=24.5

Qin Luo, School of Public Finance and Taxation,SLUC

? (2) Exemption with progression ? Suppose all the income is domestic, then the tax rate would be 40%. ? Tax: 70*40%=28
? Exercise: ? Suppose country A adopts super progressive tax rate.
Qin Luo, School of Public Finance and Taxation,SLUC

? The average tax rate ? =(80*35%+20*40%)/100=36%<40% ? Tax: 70*36%=25.2

Qin Luo, School of Public Finance and Taxation,SLUC

? Exercise 2
France 290,000 <300,000: 30% 300,000—350,000: 40% >350,000: 50%
Qin Luo, School of Public Finance and Taxation,SLUC

Germany 68,000 30%

? 4. advantage and disadvantage: ? Advantage: ? The exemption method is relatively simple for the tax authorities to administer and is effective in eliminating international double taxation.

Qin Luo, School of Public Finance and Taxation,SLUC

? For the partial exemption system to work effectively, a country must be able to ensure that the exemption is limited to foreign source income that is subjective to foreign tax comparable to domestic tax.

Qin Luo, School of Public Finance and Taxation,SLUC

? disadvantage: ? (1) The exemption with progression system is more complex. ? (2) It offends against the tax policy objectives of fairness and economic efficiency. ? (why? See p34, p5) ? Therefore, a full exemption method of relieving double taxation is difficult to justify and is used by few countries.
Qin Luo, School of Public Finance and Taxation,SLUC

? (3) One weakness of an exemption system is its likely impact on the shifting of tax burdens from the earner to the income payer. ? Example 3 : p36 (also see p26.p2)

Qin Luo, School of Public Finance and Taxation,SLUC

4.3.3 Credit Method
? 1. Definition: ? Foreign taxes paid by a resident of a country are credited against the residence country’s tax on the resident’s foreign-source income. ? The credit method completely eliminates international double taxation of the residencesource type.

Qin Luo, School of Public Finance and Taxation,SLUC

? For example, T Co. is the resident of country A and has a branch in country B.
Country A income tax rate 8000 (1) 30% (2) 30% Country B 2000 30% 20%

(3) 30%
Qin Luo, School of Public Finance and Taxation,SLUC

40%

domestic tax before credit (1) Foreign tax Foreign tax credit

10 000*30%=3 000 (2) (3)

2000*30%= 2000*20%= 2000*40%= 600 400 800 600 400 600 3000-400 =2600 3000-600 =2400

Final 3000-600 domestic tax =2400

Qin Luo, School of Public Finance and Taxation,SLUC

? ? ? ?

Under the credit method: (1) full credit (2) ordinary credit foreign-source income is subject to domestic tax whenever the foreign tax rate is less than the domestic tax rate.

Qin Luo, School of Public Finance and Taxation,SLUC

? Credit countries invariably do not pay tax refunds when their taxpayers pay a foreign income tax at an effective rate that is higher than the domestic effective tax rate. ? Nor do they allow the excess foreign tax to offset taxes imposed on domestic income.

Qin Luo, School of Public Finance and Taxation,SLUC

? In other words, the credit for foreign taxes paid is usually limited to the amount of the domestic tax payable on the foreign-source income (limitation on the credit). ? Excess foreign tax credit ? =foreign tax – limitation on the credit ? foreign tax credit balance ? = limitation on the credit – foreign tax
Qin Luo, School of Public Finance and Taxation,SLUC

4.3.3.1 General Rules
? Resident taxpayers are treated equally from the perspective of the total domestic and foreign tax burden, except if foreign taxes exceed domestic taxes. ? Moreover, subject to the same exception, the credit method is neutral with respect to a resident taxpayer's decision to invest domestically or abroad. ? Example 4: p37.p3
Qin Luo, School of Public Finance and Taxation,SLUC

? Many countries allow excess foreign tax credits to be carried forward and credited against domestic taxes in future years. ? The carry-forward period differs from country to country. Such as Canada 7 years, USA 5 years, Japan 3 years, China 5 years.

Qin Luo, School of Public Finance and Taxation,SLUC

? Besides carry forward, carry backward is also allowed in some countries. For instance, Canada 3 years.
? Some other countries ,such as Germany, Luxembourg and France allow the excess foreign tax credits to be deducted as current expenses.
Qin Luo, School of Public Finance and Taxation,SLUC

? Example 5,

limitation Foreign tax 2010

excess 5

balance Domestic tax

2011 15

10
Qin Luo, School of Public Finance and Taxation,SLUC

5

30

? (1) carry-forward is not allowed: ? The effective credit is 10 and the final domestic tax is 20 (30-10). ? (2) carry-forward is allowed: ? The effective credit is 15 and the final domestic tax is 15 (30-15).

Qin Luo, School of Public Finance and Taxation,SLUC

? On tax policy grounds, the credit method is generally recognized to be the best method for eliminating international double taxation.
? However, the operation of a foreign tax credit system can be complex from both the government and taxpayer sides. (p38)

Qin Luo, School of Public Finance and Taxation,SLUC

? A foreign tax credit system may encourage a source country to increase its taxes on income earned by nonresidents to the level of tax in the country of residence (so-called "soak-up" taxes).

Qin Luo, School of Public Finance and Taxation,SLUC

4.3.3.2 Types of Limitations
? Countries use a variety of types of limitations. ? 1. overall or worldwide limitation: ? ----The credit is limited to the lesser of the aggregate of foreign taxes paid and the domestic tax payable on the total amount of the taxpayer's foreign source income. ? This method permits the averaging of high foreign taxes paid to some countries with low foreign taxes paid to other countries.(p39,p3)
Qin Luo, School of Public Finance and Taxation,SLUC

? 2. country-by-country limitation
? ----the credit is limited to the lesser if the taxes paid to each foreign country and the domestic tax payable on the taxpayer's income from each country. ? This method prevents the averaging of high and low foreign taxes paid to various countries, but it permits the averaging of high and low rates of foreign tax paid to a particular country on different types of income. (p39,p4)
Qin Luo, School of Public Finance and Taxation,SLUC

? 3. item-by-item limitation ? ----the credit is limited to the lesser of the foreign tax paid on each particular item of income and the domestic tax payable on that item of income. ? This method prevents averaging and is probably the best method from a theoretical perspective, although few countries use it in practice.
Qin Luo, School of Public Finance and Taxation,SLUC

? Example 6: p40-42 ? Example 7:Compute the limitation on credit and the tax payable of R Co. to country A using the overall and country-by-country limitation methods respectively.
country A B C company Controlling, R Branch, S income payable 1000 100 tax rate 50% 60% 40% 60 40 foreign tax

Branch,Qin T Luo, School 100 of Public

Finance and Taxation,SLUC

? ? ? ? ? ?

Total tax before credit =(1000+100+100)*50%=600 (1) overall limitation: Limitation on credit: (100+100)*50%=100 Foreign tax: 60+40=100 Country A tax after credit: 600-100=500

Qin Luo, School of Public Finance and Taxation,SLUC

? ? ? ? ? ? ?

(2) country-by-country limitation: Country B limitation: 100*50%=50 Country C limitation: 100*50%=50 Country B tax: 60 Country C tax: 40 Country A tax after credit: 600-50-40=510 Q:Suppose the income taxable of T Co. is -50.
Qin Luo, School of Public Finance and Taxation,SLUC

? ? ? ? ? ?

Total tax before credit =(1000+100-50)*50%=525 (1) overall limitation: Limitation on credit: 525*(100-50)/1050=25 Foreign tax: 60 Country A tax after credit: 525-25=500

Qin Luo, School of Public Finance and Taxation,SLUC

? ? ? ? ? ?

(2) country-by-country limitation: Country B limitation: 100*50%=50 Country C limitation: 0 Country B tax: 60 Country C tax: 0 Country A tax after credit: 525-50=475

Qin Luo, School of Public Finance and Taxation,SLUC

? In conclusion, ? when the foreign branches make a profit, overall limitation method can decrease the tax burden of the taxpayer.
? When some foreign branches make a loss, country-by-country limitation method can decrease the tax burden of the taxpayer.
Qin Luo, School of Public Finance and Taxation,SLUC

? In practice, more countries adopt the countryby-country limitation method, such as U.K., Germany, Finland.

Qin Luo, School of Public Finance and Taxation,SLUC

? Note: ? The three methods for limiting the foreign tax credit are not mutually exclusive. ? For instance, the U.S. uses this type of hybrid method, i.e. separate baskets approach.(p42)

Qin Luo, School of Public Finance and Taxation,SLUC

? China: ? EIT: country-by-country ? IIT: country-by-country and item-by-item

why?

Qin Luo, School of Public Finance and Taxation,SLUC

? Assignment 3-1: T Co is the resident of China. Its domestic income taxable is 3000,000 in 2008. Its income earned abroad is as follows:
Country A Business income 1500,000 Royalty 500,000 Country B Rent 300,000 Interest 500,000 Royalty 200,000
Qin Luo, School of Public Finance and Taxation,SLUC

40% 15% 20%

? All income earned abroad is taxed by local government. ? Compute the foreign tax credit and the actual tax payable T Co should pay to China.

Qin Luo, School of Public Finance and Taxation,SLUC

? Assignment 3-2: ? Mr. Li earned income 79,600 from country A in 2010, including payroll 69,600 (average 5,800 per month) from one company and service income 10,000. He paid tax 2100 to country A. Besides, he earned royalty 30,000 from country B and also paid tax 6,000. ? Compute the foreign tax credit and the actual tax payable Mr. Li should pay to China.
Qin Luo, School of Public Finance and Taxation,SLUC

Assignment 3-1:
? ? ? ? ? ? ? ? Country A limitation: (1500,000+500,000)*25%=500,000 Country B limitation: (300,000+500,000+200,000)*25%=250,000 Country A tax: 1500,000*40%+500,000*15%=675,000 Country B tax: (300,000+500,000+200,000)*20%=200,000
Qin Luo, School of Public Finance and Taxation,SLUC

? total tax before credit: ? (3000,000+2000,000+1000,000)*25%=1500,000 ? Tax after credit: ? 1500,000-500,000-200,000=800,000

Qin Luo, School of Public Finance and Taxation,SLUC

Assignment 3-2:
? ? ? ? ? ? ? ? (1) country A limitation: Payroll: Per month: (5800-4800)*10%-25=75 Per year: 75*12=900 Service:10,000*(1-20%)*20%=1,600 Total limitation: 900+1600=2500 (2) country B limitation: 30,000 *(1-20%)*20%=4800
Qin Luo, School of Public Finance and Taxation,SLUC

? Country A: ? Mr. Li should pay 400 (2500-2100) to China. ? Country B: ? The tax paid 6000 is more than the limitation 4800, so the excess foreign tax credit 1200 can only be carried-forward in the following 5 years.
Qin Luo, School of Public Finance and Taxation,SLUC

4.3.3.3 Indirect or Underlying Credit
? 1.definition: ? The indirect credit is a credit granted to a domestic corporation for the foreign income taxes paid by a foreign affiliated company.
? The amount allowable as credit is the amount of the underlying foreign tax paid by the foreign affiliate on the income out of which the dividend was paid.
Qin Luo, School of Public Finance and Taxation,SLUC

? underlying tax: 母公司从国外子公司分得 的股息必然会负担的子公司所在国的税款 ? 2. condition: ? To claim a credit for taxes paid by a foreign affiliate, the domestic corporation must own at least a minimum percentage, usually 10% of the capital of the foreign corporation. ? China?
Qin Luo, School of Public Finance and Taxation,SLUC

? 3. example: page 42-43
? 4. The credit for withholding tax is a direct credit but not an indirect credit, because the domestic company itself is treated as the payer of the withholding tax.

Qin Luo, School of Public Finance and Taxation,SLUC

? 5. Appraisal: ? (1) The credit method may have the effect of discouraging domestic corporation that have earned profits abroad through foreign affiliates from repatriating those profits as dividend distributions. ? (2) The rules designed to govern the indirect foreign tax credit are typically the most complex part of a foreign tax credit system.(p44,p2p3) Qin Luo, School of Public
Finance and Taxation,SLUC

Example 8:
? X国母公司A拥有Y国子公司B的50%的股份。A公 司在某纳税年度在X国获利100万元,B公司在同 一纳税年度在Y国获利200万元,缴纳公司所得 税后,按股权比例向母公司支付毛股息,并缴 纳预提所得税;X国公司所得税税率为40%,Y 国公司所得税税率为30%,Y国预提所得税税率为 10%。 ? 计算X国A公司的间接抵免额及向X国的应纳税额 。

Qin Luo, School of Public Finance and Taxation,SLUC

Country X
50%

Country Y B Co. dividend

A Co.

1000,000 40%

2000,000 30%, 10%

Qin Luo, School of Public Finance and Taxation,SLUC

? Country Y tax:200*30%=60 ? profit after tax:200-60=140 ? Gross dividend B Co. should pay to A Co.: 140*50%=70 ? Withholding tax:70*10%=7 ? Underlying tax of A Co. :60*70/140=30 ? Total income of A Co. from B Co.:70+30=100 ? Limitation on credit:100*40%=40
Qin Luo, School of Public Finance and Taxation,SLUC

? Because all the tax paid to country Y directly and indirectly is 37,less than the limitation 40,the allowed tax credit is 37.
? Tax payable before credit to country X: (100+100)*40%=80 ? Tax payable after credit to country X: ? 80-37=43
Qin Luo, School of Public Finance and Taxation,SLUC

? Example 9: (selected) ? Assume Co A control 50% share of Co B and Co B control 50% share of Co C.
Income Co A Co B Co C 200 200 100
Qin Luo, School of Public Finance and Taxation,SLUC

Tax rate(%) 40 30 20

China’s indirect credit
? 我国过去税法一直不允许企业办理外国税收 间接抵免,而2008年新所得税法则允许: ? Article 24 居民企业从其直接或间接控制的外 国企业分得的来源于中国境外的股息、红利 等权益性投资收益,外国企业在境外实际缴 纳的所得税税额中属于该项所得负担的部分 ,可以作为该居民企业的可抵免境外所得税 税额,在本法第23条规定的抵免限额内抵免 。
Qin Luo, School of Public Finance and Taxation,SLUC

? 《实施条例》: ? Article 80 我国居民企业办理间接抵免的 直接控股比例为20%以上(含20%),间 接控股(按连乘法计算)也要求20%以上 (含20%)。 ? 财税【2009】125号 ? 总局公告2010年第1号
Qin Luo, School of Public Finance and Taxation,SLUC

4.3.4 Comparison of the exemption and credit methods
? (1) very few counties have either a pure exemption system or a pure credit system. ? (2) For most countries using the exemption method, the exemption of foreign source income is restricted to certain active business income. ? (3) The two methods are reasonably comparable if designed properly. (p45) ? Also p30-31
Qin Luo, School of Public Finance and Taxation,SLUC

? Suppose the domestic effective rate is R1 and the foreign effective rate is R2. ? R1=R2, or R1<R2: same results; ? R1>R2: exemption method is better for the taxpayer

Qin Luo, School of Public Finance and Taxation,SLUC

4.5 Tax Sparing
? 1. Definition:
? A tax sparing credit is a credit granted by the residence country for foreign taxes that for some reason were not actually paid to the source country but that would have been paid under the country's normal tax rules. ? ( or see p168)
Qin Luo, School of Public Finance and Taxation,SLUC

? ? ? ? ?

Source country:
To attract foreign investment → tax holiday or other tax incentive → the effective tax is lower than the nominal tax

Qin Luo, School of Public Finance and Taxation,SLUC

? Without tax sparing, the reduction in sourcecountry tax will be replaced by an increase in residence country tax.
? So the actual beneficiary of a tax incentive provided by a source country to attract foreign investment may be the residence country rather than the foreign investor.
Qin Luo, School of Public Finance and Taxation,SLUC

? 2. Example 10: P51 ? Example 11: ? M Co. of country A has a branch, N Co. in country B. N Co. made a profit 100 in 2011. The tax rate of A is 40%. The tax rate of B is 30%. In order to afford tax incentive to foreign investor, the tax rate of B is decreased to 10%. ? Please analyze the country A tax of N Co.. ? (1) without tax sparing ? (2) with tax sparing
Qin Luo, School of Public Finance and Taxation,SLUC

? (1) without tax sparing: ? Country B tax: 100*10%=10 ? Country A tax: 100*40% - 10=30
? (2) with tax sparing: ? Country A tax: 100*40% - 100*30%=10

Qin Luo, School of Public Finance and Taxation,SLUC

? 3. Tax sparing is primarily a feature of tax treaties between developed and developing countries. ? For example, according to the statistics of Aug, 2008, in the 89 tax treaties of China entered with other countries, tax sparing is included in 48 treaties. In the 30 tax treaties with OECD countries, tax sparing is included in 25 treaties.
Qin Luo, School of Public Finance and Taxation,SLUC

? Only Greece, Ireland, Mexico, Turkey and U.S. did not agree with China on tax sparing. ? Consider: ? Why does U.S. oppose to tax sparing?

Qin Luo, School of Public Finance and Taxation,SLUC

? In all, ? 1.direct credit——legal double taxation ? 2. indirect credit ——economic double taxation ? 3. tax sparing credit

Qin Luo, School of Public Finance and Taxation,SLUC

Summary of this chapter
? 1. the reasons and types of international double taxation ? 2. relief mechanism: three methods ? 3. the role of tax sparing

Qin Luo, School of Public Finance and Taxation,SLUC


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