Law Commons^™

China, Wei Cui

Wei Cui

This overview of the current state of China’s income tax treaties highlights three themes. First, the OECD and UN Model Conventions have shaped not only the treaties that China has negotiated but also the country’s domestic tax law itself. A significant number of concepts were introduced into domestic law primarily by borrowing from the treaty framework: these transplants have sometimes enriched affiliated concepts in domestic law, but in other cases, due to the limitations in the treaty framework itself, have held back the development of domestic law. Second, there are important examples where conflicts between China’s treaty obligations and its …