《中韩税收协定》面临的挑战与对策

Abstract

China and Korea are mutually important trade partners. The Sino-Korean Tax Treaty, which has become effective since 1995, is an official source of international norms which are employed to eliminate double taxation and tax evasion and plays a very important role in promoting trades and investments between China and Korea. However, it seems that the tax treaty needs to be renegotiated in order to keep up with the changes in Chinese domestic tax law in recent years, development of international tax practices, and new forms adopted in bilateral trade and investments between China and Korea. In this regard, the author of this paper states that from the Chinese standpoint, although more attention should be paid to resident jurisdiction, source jurisdiction should be well-maintained when both parties are renegotiating the tax treaty, because generally speaking, in the Sino-Korean economic relation China is still a net capital-importing country and Korea is a net capital-exporting country in the future, taking into account the increase of outbound investment by China in recent years.