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税收专约是国际税法的国际渊源之一。税收专约与国内税法是一国税法体系的不可分割的两个部分。二者在功能与作用方面既有相同点又有不同点。税收专约与国内税法的不同表现在避免国际重复征税、解决跨国逃税与避税、税收协调、强制力;税收专约与国内税法的相同表现在维护国家税收利益、避免国际重复征税、促进国际贸易经济发展、提供公平、公正的国际税收法制环境。
Tax treaty is one of the international sources of international tax law. Tax concession and domestic tax law are two indivisible parts of a country’s tax law system. The two have similarities and differences in function and function. The difference between tax treaties and domestic tax laws is to avoid international double taxation, to solve the problem of cross-border tax evasion and tax avoidance, tax co-ordination and coercive power. The tax monopoly is the same as that of domestic tax law, which is to safeguard national tax revenue and avoid international double taxation. International trade, economic development, to provide a fair and equitable international tax environment.