Which of the followings are the main reasons for the more severe problems of international tax avoidance such as the tax base erosion and profit shifting in the near future ( )
A. The inexplicit distinction between legal tax planning and the illegal tax avoidance
B. There is great difference among income tax rate levels across countries
C. The income tax rules of different countries don't consist with each other
D. The current international tax rules are difficult to apply to taxation of digital economy transactions
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Which of the following acts of taxpayers does not belong to international tax evasion ( )
A. To conceal the amount of income of overseas property, not declaring the true amount
B. Do not give price based on a fair market price in related party transactions
C. To set up brand companies in tax havens to transfer accumulated profits
D. To fabricate equity investment as loan investment
In the following foreign enterprises, which does not meet the requirements of the control standards stipulated in the controlled foreign companies taxation in China ( )
A. Foreign enterprises with their actual administration inside China
B. Foreign enterprises with their chairmen as individual Chinese residents
C. Foreign enterprises with their more than 50 percent shares held by Chinese residents
D. Foreign enterprises whose funds and purchases and sales are subject to the substantive control of Chinese resident shareholders
Which of the following principles have features of general anti-avoidance rules ( )
A. Independent trading principles
B. Substance is superior to form
C. Principle of reasonable business purpose
D. Reasonable cost-sharing principle
In accordance with permanent establishment principle in a double taxation agreement, which of the following countries can collect tax on the profit income from permanent establishment ( )
A. Country of the place where a permanent establishment is located
B. Country of residence of the company to which the permanent establishment belongs
Country of the place where the payer of the operating income of the permanent establishment is located
D. Country of the place where the business property of the permanent establishment is located