随着国际市场的形成,跨国公司日益加速其资金、技术和劳务的国际流通,促进了国际经济的发展,带来了个人应税所得的国际化。在此情况下,调整主权国政府与纳税人的征纳关系和有关国家之间的税收分配关系,就成为重要课题。在个人应税所得额的确定上,存在着两个层次的问题。第一层次的问题是主权国家之间税收管辖权行使问题。有关主权国出于税收的要求,除受税收协定的限制外,都采取最适合的、最好的原则来行使税收管辖权。从居住国 With the formation of the international market, multinational corporations are increasingly accelerating the international circulation of capital, technology and labor services, promoting the development of the international economy and bringing about the internationalization of personal taxable income. Under such circumstances, it has become an important issue to adjust the relationship between the government of the sovereign state and the taxpayers and the taxation distribution among the countries concerned. In determining the amount of personal taxable income, there are two levels of problems. The first level of issue is the issue of the exercise of tax jurisdictions among sovereign nations. Concerning the requirements of the sovereign state for taxation, except the restrictions of the tax treaty, the most appropriate and best principle is adopted to exercise tax jurisdiction. From the country of residence