From Source-oriented to Residence-oriented: China’s International Tax Law Reshaped by BRI

Abstract

The Belt and Road Initiative (BRI), as one of the most remarkable events of international economic cooperation nowadays, has noticeable implications for many areas of study. This article is to explore how BRI, an initiative proposed and championed by China, has influenced China’s international tax system. To answer the question, the article sets two guideposts for depicting a country’s position of international tax policy, namely, the source-oriented tax system and residence-oriented tax system. Based on that, this article puts forward the proposition that there is a trend that China’s international tax system is transforming from source-oriented to residence-oriented. To verify the proposition, this article uses a conceptual and factual approach to analyze the rule-based changes driven by BRI. And those changes are from two aspects, the domestic tax law and the bilateral tax treaty. In addition to them, the top design of BRI with particular reference to international tax policy will be discussed beforehand. In the end, the article is concluded by regarding the proposition as tenable.