本教材考察了体现于众多税收条约和国内法的连贯一致的国际税收体系，以及其作为国际法重要组成部分的路径，无论是基于条约还是基于惯例。其实践性内涵还在于：各国不能任意它们喜欢的国际税收规则，而只能在国际税收体系的背景下运作。当国际法随时间的迁移发生变化时，这个体系也会同样发生变化。因此，单边行动虽然不是没有可能，但是也会受到限制，各国通常都不愿采取违反这个体系基本准则的单边行动，阐释了国际税收体系的结构，也详尽分析了美国税法如何体现其根本准则。
Preface
This textbook on international tax law follows the common pattern of similar works in the field, that is, to provide an introductory analysis of the issues about how a country (eg, China) should design its income tax rules and coordinate those rules with the income tax systems of its trading partners (eg, US or EU), and what taxpayers should keep in mind when they pay income taxes transnationally under such rules and systems However, the work tries to feature a balance between ‘introduction’ and ‘inspiration’ To do this, the work pays special attention to four interconnected factors
First, the target readers The work is especially intended for students with backgrounds in laws, international politics and/or international economics Therefore, it encourages and shows how to apply the critical thinking based on the observation of international tax rules through the prism of international politics and economics Second, the focus of the discussion The work does not focus on technical details; especially, it is not a manual for international double taxation relief or international tax planning To know ‘what’ and ‘how’ is of course important, but knowing ‘why’ is often more fundamental The work emphasises the underlying principles and general framework of international taxation By learning such principles and framework, the students need not worry that their knowledge will soon be outdated with any updates of the tax rules and practices Third, local thinking The domestic tax systems in different countries vary widely to suit their economic, social and political needs Against the background of discussing the underlying principles, the general framework, and common practice of major rulesupplying countries, the work has a dedicated chapter on Chinese income tax rules which will make it easier to get the full picture of Chinas international taxation administration Fourth, selflearning Besides cases and illustrations pertinent to different situations, the work attaches some questions (most are open questions) to different parts for readers further thinking These questions are especially designed for the target students
Nevertheless, this work would also be helpful to anyone who is interested in international business transactions and wants an overview of the legal rights and duties as an international taxpayer and the most frequent method for resolving taxation disputes at international level Please note that the author is not engaged in rendering legal or other professional advice and this work is not a substitute for the advice of an attorney If you require legal or other expert advice, you should seek the services of a competent attorney or other professional
The author has used his best endeavours to ensure that the URLs for websites referred to in this work are correct However, the author has no responsibility for the websites and can make no guarantee that a site will remain live or that the content is or will remain appropriate
国际税法
Preface
Acknowledgements
The author would like to thank Professors Zhang Lantao, Fu Kajia, Zhang Shiquan, Wu Xiangying and Tao Jian from University of International Relations, Beijing (UIR), Prof Wang Jun from University of International Business and Economics, Beijing (UIBE), and undergraduate students of UIR and international students of UIBE whoever took this class
Dedication
The work is dedicated to my family
Chen Weiguo
Beijing, 25 June 2015
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