Which of the following cross border transaction arrangement or behavior can constitute abuse international tax agreements to avoid tax ( )
A. Income from interest on loans originating in the territory of the other Contracting State received and transferred by a resident company of one Contracting State through an agent located in a tax haven.
B. Income from the interest on loans obtained by receiving and transferring by a resident company of a Contracting State on behalf of its subsidiary established in a third country through the parent company in the territory of the other Contracting State.
C. Interest on loans originating in the territory of the other Contracting State obtained by receiving and transferring of a branch within the territory set by a third country resident enterprise within the territory of the Contracting State.
D. A third-country residents authorize a resident of a Contracting State to collect and transfer interest on loans originating in the territory of the other Contracting State on behalf of it.
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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
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
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