| 英文摘要 |
As a result of the BEPS Action Plan, the limitation on benefits rule, which is aimed at preventing treaty shopping, has become an OECDrecommended rule. The importance of the rule has been significantly elevated, and an increasing number of countries have adopted this rule under the impact of the BEPS project. The limitation on benefits rule has been incorporated in five of the Chinese tax treaties, and China has been actively responding to the BEPS Action Plan, therefore it is necessary to have a thorough understanding of the concept of treaty shopping and the limitation on benefits rule, especially the theoretical underpinnings and the rationales for the design of the rule. For this reason, it is hoped that thisarticle will provide useful information and analysis for policy makers to better understand and evaluate the rule, and respond to the BEPS project.
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