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双重课税协定 Double Taxation Agreement (DTA) [2]

论文作者:www.51lunwen.org论文属性:本科毕业论文 Thesis登出时间:2017-12-13编辑:cinq点击率:16392

论文字数:3000论文编号:org201712131417395113语种:英语 English地区:美国价格:免费论文

关键词:税收留学生论文双重课税协定

摘要:本文是留学生税收论文范文,主要内容是解释双重征税协定相关内容及其发展史,以及税收协定所存在的局限性。

The first bilateral agreement was signed between Prussia and Austria in 1899. In 1909 a bilateral DTA was signed between Hungary and Austria. However, it is only after the World War I that the League of Nations began its investigation on the issue of juridical double taxation following an appeal made by the 1920 Brussels International Financial Conference. A report on Double Taxation made by eminent economists worldwide was submitted to the Economic and Financial Commission in 1923 and this very report emerged as the basis of the first draft model DTA and was published in 1928. The allocation of taxing rights to a taxpayer’s country of residence on cross border transaction was endorsed by this model treaty. But as the scope of the 1928 draft model was not very broad and it led the League of Nations to set up a Fiscal Committee to further expand its scope in 1929. The Fiscal Committee produced a draft model in 1933 but it was never adopted although it was revised in 1935.

The Fiscal Committee of the League of Nations continued its research and finally in a regional conference in Mexico City in 1943, the representatives from North and South American countries produced another draft model. This draft model recognized that primary taxing rights remain with the source country and which was obviously advantageous for developing countries. However, this draft model was reviewed and revised in London in 1946 and it restored the original proposition where the primary taxing rights were conferred to the resident countries. It was only in 1960 that the Fiscal Committee of the Organization for European Economic Co-operation (OEEC), which was later renamed as the Organization for Economic Cooperation and Development (OECD) started gearing the developments of the double tax treaties on the international sphere. In 1963 the first OECD draft model was presented and it confirmed the interest of developed countries by allocating the taxing rights to a taxpayer’s country of residence. In 1963 a draft model was already finalized and it was only in 1977 that the model Double Taxation Convention was publicly released. The 1963 draft in fact contained an amalgamation of the four earlier drafts and it also included the 1958 draft model. This is the reason why the birth of the OECD model is usually considered to be 1 July 1958. The global economy being vibrant and prone to rapid changes, the OECD Model required constant review to address all the emerging tax issues. The Working Party No. 1 of the OECD's Committee on Fiscal Affairs meets this need and its work results in regular changes to the Model. Updates were published in 1994, 1995, 1997, 2000, 2003, 2005, 2008, 2010 and 2014.

The United Nations Model Convention (UN MC)

The Economic and Social Council of the United Nations in its resolution 1273 (XLIII) adopted on 4 August 1967 had mandated the Secretary-General to set up an ad hoc working committee comprising of experts and tax administrators selected by Governments, but acting in their own capacity, both from developed and developing countries and being an sufficient representation of the all the regions and tax systems, with the task of exploring, in consultation with interested international agencies, ways and means for facilitating the conclusion of tax treaties between developed and developing countries, including the formulation, as appropriate, of possible guidelines and techniques to be used in such tax tre论文英语论文网提供整理,提供论文代写英语论文代写代写论文代写英语论文代写留学生论文代写英文论文留学生论文代写相关核心关键词搜索。
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