跨国电子商务中国际税收管辖权的冲突及对策

随着网络技术的发展,电子商务正以其空前的无限生命力推动着部门经济、区域经济、国民经济和世界经济跃上一个新的台阶,但同时电子商务也对国际税收利益的分配形成了巨大的冲击.电子商务环境下,国际税收征管管辖权的冲突加剧,产生国际税收征管管辖权冲突的主要原因是"常设机构"概念受到挑战,要解决电子商务发展给税收征管工作带来的问题,必须结合变化了的经济形势需要,进一步调整和完善现行税收征管法的具体内容,以加强税收征收和管理,维护我国的税收利益.     

Company Taxation and Merger Incentives in International Oligopoly: on International Policy Coordination with Strategic Trade

We analyse how national taxation of firms is likely to affect merger incentives in international markets. In particular, we ask whether non-coordinated trade policies stimulate cross-border mergers that are overall inefficient, and if this then is an argument for international coordination of such policies? We address this issue in a setting where policy makers use two-part tariffs to tax exporting firms. The analysis reveals that while non-coordinated policies may induce cross-border mergers by allowing the firms in question to play national policy makers out against each other, this can nevertheless be overall welfare enhancing compared to market outcomes under coordinated policy making.     

中国的涉外税法与国际惯例及WTO规则的冲突与协调

中国涉外税法与国际税收惯例及WTO的规则在经济全球化的进程中存在许多冲突,特别是在涉外所得税与关税方面,对于税收管辖权、税收优惠、防范国际避税、国际税收协定等方面的规定。分析涉外税法与国际税收惯例、WTO的一些规则及相互冲突等问题,并对中国涉外税法及适用进行相应的一些改革,这对于达到与国际税收惯例及WTO规则的协调很有必要。     

Designing an International Marketing Research Course

Given the ever increasing importance of international marketing research, business schools wishing to emphasize the international dimension should offer a course-on this topic. Such a course should discuss the environment in which international marketine research is conducted. Attention should be focused on the mark&ng environment, government environment, legal environment, economic environment, structural environment, informational and technological environment, and sociocultural environment. The course should also cover a discussion of how the six steps of the marketing research Drocess. namelv. Problem Definition. Develo~ine an ~ p ~ r g a c h , ~esearch ~ e s i p ~&ulation, Field ~&k/Data koE lection, Data Pre~aration and Analysis, and Re~ort Pre~aration and Presentation, shobld be implementkd in an int&nation& setting. A framework for the design of an international marketing research course is presented and the course content is discussed.     

The Greening of International Marketing

In the instruction of an international marketing course, what should be taught or elaborated oa regarding the "green" movement? Is this an exclusively American idea that belongs in the discussion of domestic marketing current events? Should a student's sensitivity be raised concerning the environment on an international scale? Or should the topic of "green marketing" be taught as a ethical business issue? In this paper, we attempt to examine the "green marketing" issue and provide a foundation from which it may be addressed in the international domain.     

How Should International Accounting Be Taught?

In the current competitive environment of the global marketplace, business students must understand the international aspects of business. Both the AACSB and AAA have emphasized adding such a dimension to the business curriculum. Several business schools have already started or have plans to start introducing an international orientation to their programs. In this article, the authors present a balanced and comprehensive curriculum for an internalional accounting course. It is our contention that international accounting be viewed from both an internal and external perspective. An internal orientation provides the specifics for the course and may be seen as the technical component The external perspective, inspired by the international business discipline, provides a more general focus and is useful for acquiring a sensitivity to why accounting processes have to differ across national boundaries. Such a view is consistent with the recommendations of the AAA Committee on Future Structure, Content, and Scope of Accounting Education.     

Who bears the burden of international taxation? Evidence from cross-border M&As

Cross-border M&As can trigger additional taxation of the target's income in the form of non-resident dividend withholding taxes and acquirer-country corporate income taxation. This paper finds that this additional international taxation is fully capitalized into lower takeover premiums. In contrast, acquirer excess stock market returns around the bid announcement date do not appear to reflect additional taxation of the target's income. These findings suggest that international taxation is considered to be burdensome and that the incidence of this taxation is primarily on target-firm shareholders.     

Cross-Border Influences in the International Business Curriculum

International business education has as much value as a component of a liberal arts program as it has in a professional business program. At Bucknell University, resource constraints have demanded that an international business course serve a wide variety of students. This article describes the structure and content of such a course and the role it plays in both business and liberal arts curricula. This expanded concept of international business has implications for larger institutions as well as requiring that new research directions be pursued.     

Faculty Perspectives on International Accounting Topics

ABSTRACT

The purpose of this study was to provide insight as to the relative importance of various international accounting topics. A survey of all accounting professors listing an international specialization in the Accounting Faculty Directory was conducted in the fall 1991. The findings should be helpful in the design of an accounting course or curriculum regarding international issues.     

刍议国际投资协定中的税收仲裁机制——以中国的缔约实践为例

为减少与包括WTO协定和避免双重征税协定在内的其他涉税条约争端解决机制之间的冲突,特别是,避免原有的投资者与国家间投资仲裁机制对本国税收主权的过度限制,中国晚近缔结的国际投资协定引入了专门的税收仲裁机制。这一尝试值得期许。然而,该税收仲裁机制仍存在诸多的不足,这可能会削弱其应有的作用。对此,中国应参考有关国家的实践,作出相应的调整。     

数字经济国际税收改革:理论探源、方案评析与中国抉择北大核心CSSCI

数字经济国际税收改革是百年变局之际世界格局转换的焦点问题之一。数字经济加剧了全球化中的经济失衡,导致市场国征税权随之兴起,国际社会随之提出了税改的初步依据,但是仍需结合政府征税原理创新展开进一步探索。综观以经合组织双支柱为代表的市场国征税权改革方案,在数字经济居民国与市场国、政府征税与跨国公司避税、发达国家与发展中国家的复杂博弈中,“选择性”改革和复杂的规则设计展示了重大历史进步意义,但也凸显了欧美的妥协及其对既得利益的保护,同时更阻断了发展中国家对工业经济税基公平权的追溯,压制了落后地区和新兴行业启动经济的发展权。作为全球数字经济第二大国的中国,基于发展中社会主义市场经济的基本前提和税基安全、公平和发展的复杂目标,需要审慎参与反避税全球竞争与合作、全面协调数字经济与实体经济平衡、科学安排税收收入与经济成长的战略关系,才能在增强以中国为代表的发展中国家在税收和经济利益上的全面的、实质性公平权利的前提下,推动形成更加科学合理的国际税收秩序。     

浅议电子商务税收对策研究

电子商务在全球范围内迅速发展，对现有经济运行及管理模式产生了极大的冲击。传统的税收制度对此无法适应，由此引发了征管稽查难度加大、网上交易国际税收问题加剧、政府税款大量流失等一系列重大税收问题。根据国际上对电子商务征税问题的观点，结合我国电子商务发展现状，探讨电子商务对传统税收的冲击和我国电子商务税收对策。     

Content,Pedagogy, and Learning Outcomes in the International Marketing Course

Abstract

The early internationalization of business school curricula was in response to corporate needs and expectations, and the Association to Advance Collegiate Schools of Business (AACSB International) fostered changes by instituting accreditation outcomes that focused upon international content in the curriculum. By the late 1990s, a course in international marketing was standard at most accredited college and universities, and faculty in these courses reported on various approaches to teaching the course. The main objective of the current study was to examine the course content, pedagogy, and learning outcomes of current international marketing courses. As such, a content analysis of international marketing syllabi from 89 colleges and universities was conducted. Findings from this indepth analysis offer insights regarding knowledge content coverage, pedagogical strategy, and learning outcomes assessment and provide an update on the current status of teaching international marketing in schools of business.     

Organizational Learning and Market Orientation in International Marketing Education

SUMMARY

This study develops and tests a series of relationships between organizational learning and market orientation as it pertains to international marketing education. The focus is on the activities and relationships between the students, faculty, and staff in the international marketing/business program at three schools in the north, midwest, and south United States. Based on a sample of 193 undergraduate and graduate international marketing students, the results suggest that organizational learning (class and major area-based learning)-team orientation, systems orientation, learning orientation, and memory orientation-positively influences market orientation learning outcomes (i.e., intelligence generation, intelligence dissemination, and responsiveness). The major implication of the study is that the education provided to the students in an international marketing course (i.e., upper-division university course) can be enhanced by focusing on organizational learning tools as a means to increase the shared knowledge level among the Students.     

International Business Education in an International City

Internationalizing the business administration curriculum has been an ongoing concern for educators. The experience in the United States appears to have encountered certain hurdles and international business education has not yet gone into full swing. On the other hand, for those countries which depend heavily on international business, the subject is generally regarded as important. Four different groups of students in Hong Kong were surveyed. The results show slight differences in their particular area of interest. The area and course rankings, in general, are similar to the findings of studies in North America. Hong Kong students are more interested in risk assessment topics. Based on the findings, various teaching strategies can be formulated. Students' attention can be drawn to relevant global developments and teaching materials can be updated accordingly. Emphasis within each course can also be adjusted each term in view of students' needs. Thus, in order to successfully internationalize a business program, both students,and instructors should be well-versed in global politics, in changes in economic situations and in major events happening in the world.     

Strategically Rethinking the Executive MBA International Business Experience

SUMMARY

During the past few years, Executive MBA (EMBA) programs at U.S. universities have expanded both in number and in content. As part of this expansion, an international experience has become an integral part of many of these programs. In most instances, the international experience has been a course planned and organized from a convenience perspective. This research proposes a more rigorous strategic planning model for EMBA program directors to consider in order to enhance the learning experience for participating students. Using a case example, it delineates between international field studies and international residencies, develops propositions, and offers an application of the proposed planning model.     

A Case Study in Project-Based Learning: An International Partnership

As our world becomes more integrated, international business students should develop skills that match corporations' needs. Moreover, students need hands-on, problem-solving, team-based, critical-thinking skills that companies demand. Students need international business experience but many of them lack the funds or support to study or intern abroad. This article explains how one program developed a project-based course that addressed these skills by partnering with a local consulate office. It lays the framework for using a project-based course, explains the course's development, outlines the necessary and important skills addressed, and provides an agenda for other schools considering such a course.     

Investigating Graduate Business Students' Perceptions of the Educational Value Provided by an International Travel Course Experience

Abstract

Researchers agree that students' critical thinking and decision making skills are enhanced through exposure to new cultures and global markets. Thus, one way of bringing about improvement in these areas is through international travel courses. The purpose of this study is threefold. One, to describe the process involved in the creation of a required for-credit international travel course; two, present the findings of a research study designed to investigate graduate business students' perceptions of the educational value provided by an international travel course; and three, describe the ongoing process of closing the assessment loop as it relates to the internationalization of MBA and MACC curricula. The results of this study are encouraging. In general, students perceived that the international travel course added value to their educational experience and enhanced their relationships with other students. Items receiving weaker support were concerned with “thinking skills”, such as multi-disciplinary integration and improved decision-making. These results have important implications for future improvements to the international travel course.     

税收执法监督的国际比较与借鉴

本文在比较分析国外税收执法监督方面的制度规定与实施情况的基础上,结合我国国情,提出可供我国借鉴的经验,并试图勾勒出我国税收执法监督尚待完善的几项制度模式,重点研究如何发挥各种不同监督方式的特色,从而形成一个多层次、高效能的税收执法监督体系。     

积极财政政策下增值税转型的探讨

增值税转型,对于应对国际金融危机以及促进我国实体经济稳定发展,都有积极而重大的作用.也是实现公平税负、保护纳税人合法权益的充分体现,更是进一步鼓励资本性投资,促进企业技术更新和发展的重要举措.本次增值税转型主要针对第二产业的机器设备实施税前抵扣,从实际运行看,改革并不彻底,存在重复征税问题.在今后的改革中,应把增值税替代营业税列为增值税改革的重点.