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以电子商务为核心的数字经济已经成为各国经济增长不可忽视的新动力,其为国民经济和世界经济的增长提供了一个全新的平台;但同时电子商务具有交易数字化、虚拟化、可控性差等特点,也为传统税收法律制度带来了严峻挑战,尤其是所得税的税收管辖权归属问题。随着跨境电子商务的发展,居住国和来源国税基的流失问题已经引发了国际社会的高度关注,故而具有来源国和居民国双重身份的中国必须重视税收管辖权的归属问题。
The digital economy with e-commerce at its core has become a new impetus that can not be ignored in the economic growth of all countries. It provides a brand-new platform for the growth of the national economy and the world economy. At the same time, e-commerce has the features of digitalization, virtualization and poor controllability Features, but also for the traditional tax legal system has posed a serious challenge, especially the income tax tax jurisdiction attribution issues. With the development of cross-border e-commerce, the loss of the tax base in the country of residence and source has drawn great attention from the international community. Therefore, China, which has the dual status of source country and resident country, must attach importance to the ownership of tax jurisdiction.