The Impact On Tax Jurisdiction Realization Of Our Country From BEPS Project

In 2013,the Organization for Economic Cooperation and Development(OECD)and G20 launched BEPS Action Plan for management of tax base erosion profits.This program aims to control the international tax avoidance problem through the 15 specific Action Plans,also to improve and develop the existing tax treaties and international transfer pricing rules,as well as to solve the problem of BEPS.Both the OECD members and non-OECD members give high priority to the BEPS Action Plan.Since September 2013,State Administration of Taxation of China established BEPS working group and integrate the related power to make in-depth research on domain rules and its influence on China,following up the project schedule pushed by OECD.State Administration of Taxation from different countries issued various documents to actively participate in BEPS Action Plan.This paper aims to analyze the positive and negative impact on China's tax jurisdiction realization from the BEPS Action Plan,putting forwards relative suggestions for getting the rational cognition and participation in this globally anti-tax avoidance activity.In terms of backgrounds,this paper introduces the basic framework of BEPS Action Plan,the status and achievements of the countries involved,and the status and role of China in the BEPS Action Plan.The parts of theoretical aspect mainly relates to the basic theories of economics and management,with the analysis of important concepts of the BEPS Action Plan such as the definitions,Game Theory,Benefit Principle,Tax Neutrality Principle,Arm's Length Principle and Substance Over Form Principle.After the introduction of the current BEPS situation in our country,this paper starts to analyze the positive and negative impact on China's tax jurisdiction realization from the BEPS Action Plan.The innovations of BEPS Action Plan are of great significance to the promotion and the construction of tax jurisdiction system in China.This paper selected 3 aspects of positive influence brought by the BEPS Action Plan included the regulations on Taxation of digital economy,strengthening on the main anti-taxavoidance rules against BEPS,the amendments on the LOB rules.This paper also discusses the negative impact from 3 aspects,included the value creation theory throughout the BEPS Action Plan which in fact protect the taxation jurisdiction of the developed countries,broad direction of some rules,as well as the unfairness in the exchange of tax informationAt the end of the article,relative suggestions on how to rationally participate in the BESP Project are put forward,mainly from the aspects of rational cognition and participation in the BEPS Action Plan and advice on promotion of tax jurisdiction realization of our country.Adequate flexibility should be maintained while strengthening the international cooperation in anti-tax avoidance.