Chapter 1Backgrounds I Introduction II Why taxation III Optimal taxation IV Goals of international tax rules V Current taxation system of China: an overview ［=§ 6 I］ Chapter 2Tax treaties and model tax conventions I Important role of international tax treaties II Treaty as main source of international laws III Legal nature and general effect of tax treaties IV Objectives of tax treaties V Model tax conventions VI Interpretation of tax treaties VII Multilateral conventions or provisions involving tax matters VIII Multilateral forums and coordinators on tax matters Chapter 3Jurisdiction to tax I Introduction II Categories of ‘jurisdiction to tax’ III General income tax liabilities under Chinese domestic laws［=§ 6 II］ IV Residence rules: defining ‘resident’ V Resident in Chinese tax laws ［=§ 6 III］ VI Source rules: determination of ‘source jurisdiction’ and source taxation VII Source taxation in Chinese laws ［=§ 6 IV］ VIII Tax jurisdictions: conclusion IX Bilateral modes helpful to resolve conflicts of jurisdictions Chapter 4Double taxation and its relief I International double taxation defined II Causes of IDT III General approach to relieve double taxation IV Relief mechanism (1): deduction method V Relief mechanism (2): exemption method VI Relief mechanism (3): credit method VII Tax sparing VIII Relief of double taxation under Chinese laws ［=§ 6 V］ Chapter 5Tax avoidance and anti-avoidance rules I Important terms II Causes of international tax avoidance III Balance of tax avoidance and countermeasures: ethics of tax avoidance, and justification of anti-avoidance measures IV Basic elements and ways of tax avoidance V Overview of anti-avoidance methods VI Thin capitalisation and thin capitalisation rules VII Use of tax deferral and CFC rules VIII Transfer pricing and its prevention IX Treaty shopping and anti-shopping clauses X Hybrid mismatch and anti-hybrid rules XI (International) tax planning and international coordination XII Special tax adjustments under Chinese laws: anti-avoidance rules on enterprise income tax ［=§ 6 VI］ XIII Conclusion: international tax law framework Chapter 6China's international taxation administration I Current taxation system of China: an overview ［=§ 1 V］ II General income tax liabilities under Chinese domestic laws［=§ 3 III］ III Resident in Chinese tax laws ［=§ 3 V］ IV Source taxation in Chinese laws ［=§ 3 VII］ V Relief of double taxation under Chinese laws ［=§ 4 VIII］ VI Special tax adjustments under Chinese laws: anti-avoidance rules on enterprise income tax ［=§ 5 XII］ References
