国内税法

税收协定优于国内税法适用不可绝对化

Tax Treaties Are Not Absolutely Prior to Domestic Tax Laws

本章中还探讨了资本弱化和股息剥离这两类特殊经济关系下某些国内税法中的股息概念。

The chapter also introduce dividend concept in thin capitalization situation and dividend-stripping situation .

应在国内税法中制定相应条款，明确规定税收抵免的主体和对象，完善对外税收协定。

Relevant provisions should be included in domestic taxation legislations to setup the subject and object of tax credit and taxation agreements with foreign countries should be completed .

尽管利息支付也是要缴纳预提所得税的，但是利息的预提所得税一般低于股息，同时各国的国内税法或者双边税收协定也会将利息的预提所得税免除。

Although the interest payments include withholding tax , it is generally lower than the dividend withholding tax , moreover , interest withholding tax could be exempt according to the domestic tax laws or the countries bilateral tax .

从国内税法中得到启示，在国际税法领域，也可以说是在国际税收协调领域，公平和效率仍然可以作为原则来使用。

Judging from the domestic tax laws of inspiration in the field of international tax law , it can be said that in the international tax area of coordination , fairness and efficiency can still be regarded as a principle to use .

各国国内税法日益趋同，世界各国的税制都倾向于以增值税为代表的间接税和以所得税为代表的直接税并行；降低税率、扩大税基成为普遍趋势。

The tax systems of the countries all over the world are inclined to adopt the indirect tax represented by value-added tax and direct tax represented by income tax and run side by side . Reducing the tax rate and expanding the tax base to become the general trend .

欧洲法院借助于共同体法有关服务、人员和资本自由流动的规则来消除成员国国内所得税法和成员国间的税收协定中阻碍共同市场发展的因素。

The ECJ eliminated barriers to common market in national legiSlation of member states and double tax conventions between member states by interpreting the EU law on free movement of persons , services and capital .

近年来，国内关于税法介绍和税收策划相关的报刊书籍汗牛充栋，可有相当一部分在与企业实际税务管理紧密结合方面做得并不够好。

In recent years , voluminous newspapers and books on the introduction of tax law and planning of tax are published in domestic . However , considerable amount of these publication were not good enough in the close combination between theory and actual tax administration of enterprises .

第二部分文献综述，对国内外关于税法遵从、税法遵从度及其评价理论进行了梳理和概括。

Section two is a bibliography which summarizes theories of tax compliance and its review both at home and abroad .

对统一我国内外资企业所得税法的思考

Some Thoughts on Unifying the Two Sets of Enterprise Income Tax in China

探讨了我国内资企业所得税法纳税主体，在结合国情并参考国外立法先例的基础上，提出新的分类意见。

In this thesis , the author probes into the issues about the taxpayer of the Income Tax Law for Domestic Enterprises of our country .