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https://nccur.lib.nccu.edu.tw/handle/140.119/31310
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| Title: | 台灣租稅協定之探討 |
| Authors: | 連玉萍 |
| Contributors: | 吳文傑
連玉萍 |
| Keywords: | 租稅協定 |
| Date: | 2005 |
| Issue Date: | 2009-09-14 09:46:34 (UTC+8) |
| Abstract: | 台灣租稅協定之探討
The motivation to conduct this research is actually assessing tax treaty applying cases is part of my work and that intrigue me to make a research on this subject. We present our research on the information excerpted from practical tax treaty applying cases of Taipei National Tax Administration in year 2003 and 2004, therefore, the outcome of this study somehow represents some meanings.
We first introduce the concepts of international tax treaty, then we bring in two models of tax treaty, namely UN Model tax Convention and OECD Model Tax Convention. Also, the ROC’s tax treaties is introducing right afterward. For conducting this study, we first established research questions based on economic rationales to observe the current situation over these 2 years. Descriptive Statistic is employed as our study method. Hence, we carry out our analysis by using the practical cases that we believe this research would present much meaningful for our study. Other than 4 main observations, some interesting phenomena were found and discussed. At last, we attached the Taiwan/ Singapore tax treaty as our appendix for readers to know that how tax treaty working from corporation and from tax authorities aspects.
However, while conducting this research, we try to put the transfer pricing issue aside. Because transfer pricing, itself, is a considerable, controversial topic which can generate tremendous discussions and papers. Besides, adding transfer pricing in our study may somehow indistinct our main subject. Therefore, we will not discuss transfer pricing here.
Abstract
Acknowledgement
Chapter 1 Introduction
Motivation and Purpose
Framework
Chapter 2 Background of International Tax Treaty
2.1 Principles
Source principle vs. Residence principle
Nationality Concern
2.2 International double taxation problem
2.3 Necessity of Tax Treaty
Chapter 3 Models of Tax Treaty
3.1 Historical Background
3.2 UN Model 2001 vs OECD Model 2000
Permanent establishment
Business profits
Shipping, inland waterways transport and air transport
Associated enterprises
Dividends, interest and royalties
Capital gains
Other income
Chapter 4 ROC`s Tax Treaties
4.1 Historical Background
4.2 List of Signed Tax Treaties
Dividends, Interest and Royalties
Guidelines for the Application of Double Taxation Agreements
Chapter 5 Research Analysis
5.1 Research Questions
5.2 Methodology
Data Source
Time Period
Samples
5.3 Sample Descriptive Statistics
By Country and its approval rate
By Service Category
Claimed income category and assessment of claims
Valid Period of Treaty Contract
How to perform service
Whether dispatch overseas representatives, if dispatch, how long do representatives stay?
Whether the contracting parties affiliated to the same multinational enterprise? If yes, what is the approval rate?
Overall approval rate
Agent for applying tax treaty and the ratio of being rejected
Chapter 6 Analysis
6.1 Cases explanation
Approved case discussion
Rejected case discussion
6.2 Samples Observation
Observation 1
Observation 2
Observation 3
Observation 4
Chapter 7 Conclusion
Appendix |
| Reference: | 鄭正輝譯（1985），租稅條約的研究，財政部財稅人員訓練所。
張慶輝，鄭文輝，郭炳伸（1989），所得稅涉外課稅問題之研究(一)，財政部賦稅改革委員會。
張慶輝，鄭文輝，郭炳伸（1989），所得稅涉外課稅問題之研究(二)，財政部賦稅改革委員會。
何國華，劉興源，羅能清（1989），所得稅涉外課稅問題之研究(五)，財政部賦稅改革委員會。
Bart Kosters, Asia-Pacific Tax Bulletin, IBFD, Jan. 2004
Coopers, Lybrand, (1989), issues pertaining to Taxation of International Income of R.O.C. companies, 財政部賦稅改革委員會.
League of Nations, report of the Fiscal Committee to the council on the work of the 5th session of the committee
Manual for the Negotiation of Bilateral Tax Treaties Between Developed and Developing Countries, United Nations, New York, 2003
Model Double Taxation Convention on Income and on Capital, OECD, Paris, 1977
OECD Model Tax Convention on Income and on Capital, Jan. 2003., OECD
OECD commentary on the Model Conventions of 1977 and 1992 (incorporating the change of 1994, 1995, 1997 and 2000)
Singapore Income Tax Act (2004)
Inland Revenue Authority of Singapore, (IRAS) available at www.iras.gov.sg
Internal Revenue Service (IRS) available at www.irs.gov
Organization for Economic Cooperation and Development (OECD) available at www.oecd.org
The United Nations (UN) available at www.un.org
The Department of Taxation, Ministry of Finance, ROC. available at www.dot.gov.tw |
| Description: | 碩士
國立政治大學
國際經營管理碩士班(IMBA)
92933010
94 |
| Source URI: | http://thesis.lib.nccu.edu.tw/record/#G0092933010 |
| Data Type: | thesis |
| Appears in Collections: | [國際經營管理英語碩士學程IMBA] 學位論文
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