Tax Sovereignty and International Tax Reform

Vol. 52, No.1 Canadian Tax Journal 141-48, 2004

5 Pages Posted: 6 Jun 2012 Last revised: 30 Oct 2013

See all articles by Jinyan Li

Jinyan Li

York University - Osgoode Hall Law School

Date Written: June 6, 2012

Abstract

The book is a study of the current state of international tax law and its application (or non-application) to electronic commerce in Canada, China, Hong Kong, Japan, Singapore, and the United States. Its purpose is to examine the extent to which current theories and principles of international taxation remain valid and the extent to which the fundamental issues need to be rethought in the age of electronic commerce.

Chapter 12 argues that the existing concepts and principles have served the world well in the “old” economy, but decreasingly serve to carve up the international tax base in a reasonable and sustainable way in the “new” economy. I discuss why the concepts of corporate residence, characterization of income, source, and permanent establishment are increasingly difficult to apply. I also analyze why transfer-pricing rules are problematic in terms of economic theory, administrative efficiency, and the interpretation of article 9 of the model tax convention prepared by the Organisation for Economic Co-operation and Development (OECD).

Keywords: tax policy, international taxation, transfer pricing, withholding taxes, sovereignty, administration

JEL Classification: K00, K34, K40, K41

Suggested Citation

Li, Jinyan, Tax Sovereignty and International Tax Reform (June 6, 2012). Vol. 52, No.1 Canadian Tax Journal 141-48, 2004, Available at SSRN: https://ssrn.com/abstract=2078975

Jinyan Li (Contact Author)

York University - Osgoode Hall Law School ( email )

4700 Keele Street
Toronto, Ontario M3J 1P3
Canada
416-736-5025 (Phone)

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