听心 瞬间倾城结局:英文论文怎么找啊

Singapore
Ajit Prabhu. International Tax Review. London: Sep 1999. pg. 77

The Singapore government launched an Electronic Commerce Plan in 1998 to spur the growth of e-commerce, and to strengthen Singapore's position as an international e-commerce hub. The target is to have S$4 billion ($2.4 billion) worth of products and services transacted electronically through Singapore, and 50% of businesses using some form of e-commerce, by the year 2003. The plan has five main thrusts:

* Develop an internationally linked e-commerce infrastructure: Include an efficient settlement system for internet transactions between businesses, covering international trade and multi-currency payments and a well-connected logistics infrastructure. Singapore will also be positioned as a centre of e-- commerce infrastructure development.

* Jump-start Singapore as an e-- commerce hub: Focus on the sectors in which Singapore has an inherent advantage as a hub, such as a stable and excellent financial infrastructure, a transport and logistics infrastructure that is well known for its efficiency, and strong telecommunications connectivity and e-commerce infrastructures, especially in business-- to-business services.

* Encourage businesses to use e-- commerce strategically: Education and other support programmes will be put in place to help businesses exploit e-commerce to enhance their productivity and competitiveness.

* Promote use of e-commerce by the public and businesses: Enable Singapore citizens and businesses in Singapore to enjoy the benefits of e-commerce, and at the same time, create an e-commerce savvy culture.

* Harmonise cross-border e-commerce laws and policies: Enable businesses to trade confidently with overseas partners. Besides putting in place legislation that is internationally consistent, Singapore will work with its major trading partners to align each other's e-commerce laws.

The plan will be implemented through specific programmes and projects. A key supporting programme is Singapore's efforts to be a thought leader on the emerging and dynamic e-commerce scene.

TAXABLE PRESENCE

Singapore operates a territorial and receipt-based tax system. Income tax is charged only on income accruing in or derived from Singapore, or received or deemed to be received in Singapore from outside Singapore. Income tax is levied on, inter alia, gains or profits from any trade, business, profession or vocation, and any gains or profits of an income nature. If the operations of a non-resident person in Singapore give rise to gains or profits of an income nature in the hands of that non-resident in Singapore that can properly be said to accrue in or be derived from Singapore, those gains or profits will be taxable in Singapore.

The main issue to be addressed in the e-commerce context, therefore, is whether income is accruing in or derived from Singapore (ie sourced in Singapore). Unfortunately, the Singapore Income Tax Act (ITA) does not define the words "accruing in or derived from," nor does the ITA lay down guidelines for determining in which locality income is sourced.

Although judicial definitions exist, the determination of the actual source of income is a question of fact. Factors that will be taken into account in determining whether income is sourced in Singapore include:

* Where the contract of service or sale is made; * Where services are rendered or where the sale takes place;

* Where the invoice is raised;

* Where the establishment is located to which income can be attributed;

* Where proceeds are collected; * Where the cost of operations is incurred/charged; and * Where title to goods passes.

When all or most of the above activities are carried out in Singapore, there is very good reason (in the absence of special circumstances leading to an opposite conclusion) for treating the income as properly derived from Singapore. Accordingly, income so derived would be subject to Singapore tax. Conversely, if all of the above activities are carried out outside Singapore, the income would be considered sourced outside Singapore on which no Singapore tax is exigible unless it is received or deemed to be received in Singapore.

The maintenance of a computer server in Singapore that merely provides advertising or the storing of data for a non-resident enterprise in Singapore in respect of goods sold by that enterprise generally should not cause the non-resident enterprise to derive any Singapore-- source income from the sales of such goods. However, if that server is able to perform order processing, approval and fulfilment, and invoicing and collection functions in respect of goods sold by the non-resident enterprise, there would be a significant risk that the non-resident enterprise would be considered to be deriving Singapore-source trading income. In that case, the non-resident would be subject to Singapore income tax in respect of the attributable profits. It would be important to determine whether sale contracts were concluded, invoices issued, and sale proceeds collected, all through the server maintained in Singapore. To reduce the exposure to Singapore income tax, the nonresident enterprise could, to the extent possible, relocate the server to a location outside Singapore or restrict the functions of the server maintained in Singapore to those of sales promotion.

Double tax treaties concluded by Singapore, which are generally based on the OECD model treaty, somewhat modify the source-based concept of domestic income taxation by introducing the concept of a permanent establishment (PE). Although defined in Singapore domestic law, the PE concept has very little relevance to the taxation of income from the sale of goods in the absence of a treaty, and therefore would be applicable only to those Singapore non-residents that are resident in treaty countries.

Article 7 of the OECD model treaty provides that "the profits of an enterprise of a Contracting State shall be taxable only in that State unless the enterprise carries on business in the other Contracting State through a permanent establishment situated therein...." Article 5(1) of the model treaty defines the term PE as a "fixed place of business through which the business of an enterprise is wholly or partly carried on." However, article 5(4)(e) specifically excludes from the PE definition "the maintenance of a fixed place of business solely for the purpose of carrying on, for the enterprise, any other activity of a preparatory or auxiliary character."

In this regard, a server located in Singapore (other than a portable computer that is carried around) may give rise to a PE of the non-resident in Singapore by virtue of article 5(1), particularly if the server is able to perform order processing, approval and fulfilment, and invoicing and collection functions. Servers that merely provide advertising and storing of data likely would not constitute a PE since those activities are likely to be of a preparatory or auxiliary nature as defined in article 5(4)(e).

CHARACTER OF INCOME

The Singapore income tax treatment of income from the sale of soft goods through the internet (eg, newspapers, magazines, books, films, music CDs, and software) is not entirely clear. Before the advent of the internet, the transfer of software (eg, through diskettes), even if under conditions in which the transferee does not have the right to copy and distribute the software to the public, is generally treated as a licensing agreement for Singapore income tax purposes. Accordingly, Singapore withholding tax would be applicable if a payment in the nature of royalty is made to a non-resident.

Unless there is a change in practice by the Singapore tax authorities, we would expect the sale of soft goods in digitized form through the internet to be accorded similar treatment for Singapore income tax purposes. However, this approach may present an administrative problem of ensuring that individual consumers buying soft goods through the internet comply with the Singapore withholding tax requirement.

GOODS AND SERVICES TAX

Singapore levies a Goods and Services Tax (GST) on the supply of goods and services in Singapore and on the import of goods into Singapore. Certain transactions, including the export of goods and the provision of international services, are zero-rated, ie, such transactions are exempt from output GST but the supplier is entitled to credit for input GST. The fundamental issue to be addressed for GST purposes is whether the sale of soft goods, such as software and other digitized material, is a supply of goods or a supply of services.

To the extent the sale of soft goods is treated as a supply of goods, it may give rise to the following problems:

* GST is imposed on the importation of "goods" into Singapore. Generally, the Customs & Excise Department collects GST at the point of importation in respect of tangible goods imported into Singapore. However, the import of soft goods into Singapore when a Singapore customer downloads the soft goods from the internet would give rise to significant collection challenges for the Customs & Excise Department.

* In the case of exports, in practice, the taxpayer would need to substantiate that the goods are actually exported before zero-rating the transaction. Proof of export may be made through documentary evidence, including the bill of lading and delivery order. Exporters of soft goods through the internet would have to grapple with the problem of the lack of such export documentation.

To the extent the sale of soft goods is treated as a supply of services (ie, payment for a right to use, similar to a licensing agreement), the determination of the place of supply could pose a significant problem for Singapore GST purposes.

As mentioned above, the supply of services in Singapore is subject to Singapore GST. Under the GST, the place of supply of services is the place where the supplier has his business establishment or fixed establishment. If the supplier of services has such establishments in more than one country, the place of supply is deemed to be in the country where the establishment most directly connected with the supply is located.

In the context of a foreign supplier of services through the internet, the question is whether the following could result in the foreign supplier having a business or fixed establishment in Singapore:

* The accessibility of a web site housed on a server located outside Singapore through a computer in Singapore, ie, a virtual presence.

* A computer server owned by a foreign supplier is located in Singapore, but the server provides advertising or stores data.

* A computer server owned by a foreign supplier is located in Singapore and the server performs order processing, approval and fulfilment, and invoicing and collection functions.

* A computer server located in Singapore performs advertising or order processing activities but is owned by a related Internet Service Provider (ISP) or a related telecommunications service provider.

* A computer server located in Singapore performs advertising or order processing activities but is owned by an unrelated ISP or an unrelated telecommunications service provider.

Where the foreign supplier is considered to be supplying services through a business or fixed establishment in Singapore and the value thereof exceed the registration threshold, the foreign supplier will be required to charge GST for the supply of services.
（节选）
好像只有一小段有用。
有一些论文比较了各国的纳税制度，不过是十年前的，网上只有简介，不提供全文下载。

国研网上有;
另外,国内比较大的高校的图书馆有电子资源下载,也可以查阅到一些.

Smoking

It is almost known to all that smoking is bad for people's health. Scientific researchs show that smoking can lead to heart disease,cancer and other problem.The World Health Organization says diseases linked to smoking kill at least two million five-hundred-thousand persons each year.

Still,many people find it difficult to stop smoking.One reason is that smoking usually becomes a habitual behaviour,and habits,whether good or bad are not easy to be given up.Another reason is the effect of nicotine,the substance found in cigarettes works on people somewhat as drugs do.

Measures have been taken to help people keep away from the harm of smoking. In many cities,smoking is forbidden in public places.The danger of smoking is warned of everywhere.And newspapers are asked not to publish advertisements for cigarettes.World "No Tobacco Day" is observed every year as the biggest compaign against smoking.