租稅協定簡介

「租稅協定」係「避免所得稅雙重課稅及防杜逃稅協定(Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with respect to Taxes on Income)」之簡稱,為雙方締約國家為消除所得稅課稅差異對跨境投資、經貿往來及文化交流活動所形成之障礙,本於互惠原則,就前述活動所產生各類所得商訂減、免稅措施,以消除雙重課稅,甚至減輕稅負,營造有利雙方投資及人民往來之永續低稅負環境,並商訂相互提供稅務行政協助之範圍,以防杜逃稅,維護雙方稅收。

此外,也有國家僅就國際運輸所得洽簽海、空國際運輸所得互免所得稅單項協定,以相互免稅方式,解決雙方國際運輸事業雙重課稅問題,便利雙方投資、經貿及人民往來。

 

The Introduction of Taxation Agreements

 

The “Taxation Agreement” (with the full title of “Agreement for the Avoidance of Double Taxation and the Prevention of Fiscal Evasion with Respect to Taxes on Income”) is an agreement to remove taxation differences between two parties, in order to promote cross-border investment, trade and cultural exchanges. In line with the principle of reciprocity, the two parties endeavor to reduce tax rates and exempt certain incomes from taxes. The goal is to eliminate double taxation and create tax structures that promote sustainable low-tax environments that facilitate investment and people-to-people exchanges. The parties can also negotiate a scope for mutual assistance designed to prevent tax evasion and maintain taxation income for both parties.

 

In addition, some countries only negotiate an agreement that covers international sea and air shipments. Such an agreement uses tax exemptions to solve the problems of double taxation on international shipments. This arrangement is designed to assist cross-border investment, trade and people-to-people exchanges.