The Department of Finance (Canada) appointed an Advisory Panel on Canada’s System of International Taxation (the ‘Advisory Panel’) to review and recommend changes to Canada’s international tax regime. This report provides background research to assist the Advisory Panel with its...

This article reviews the major elements of the enterprise income tax (EIT) system in China and examines the dynamic relationship between international norms and the local Chinese context. After some introductory remarks, the article discusses the fundamental principles, concepts and structural...

By taking the Great Wall of China as an analogy for China's treaty policy, the author considers key aspects of China's treaty network and its implications, and whether or not this constitutes a “Great Fiscal Wall of China.”Cited with the permission of IBFD

This paper examines the investments made by China in key African countries and analyses the effects of such investment on the tax base of such African countries. The aim of this analysis is to determine whether the costs of such investment are commensurate to the benefits derived, or to be...

The desirability of doing business in any foreign country may turn on the ability to avoid double taxation. This issue is a serious concern for foreign countries. For example, in China authorities have expressed a willingness to pursue a treaty specifically removing the problem of double...

Seven years after its introduction in 2008 with the enactment of the new Chinese Corporate Income Tax Law, the Chinese general anti-avoidance rule (GAAR) has become a complex and incoherent piece of legislation. Despite its current shortcomings, the international impact of the Chinese GAAR is...

In the post-BEPS era, China, as a non-OECD member country but a member of the G20, has a positive attitude towards the implementation of the OECD/G20 BEPS Action Plan, especially in the area of treaty abuse and dispute resolution. However, the implementation presents divergence with the OECD/G20...

The recent policy literature on fiscal federalism in China has concentrated on the large "vertical fiscal gap" resulting in inadequate local provision of public goods and services. Thus there is an evident interest in giving local governments more taxing powers. After a brief historical survey,...

U.S. taxpayers and the IRS increasingly have to take into account the interactions between U.S. and foreign laws, but they have paid little attention to the administrative law backgrounds of foreign tax laws. In a growing range of cases, the need for such attention has become urgent. This...

The German law to combat VAT fraud and other tax regulations went into force recently. The German legislator aims to enforce German VAT law via a liability of platform operators (like Amazon and eBay). The consequences of this regulatory approach are a) that platform operators enforce the law...