a) describe a rule, concept, principle or regime (e.g., taxation of business profits
or taxation of technical services) in the context of the Chinese tax legislation; b) describe and compare the
Chinese domestic law with pertinent provisions in
10-15 selected Chinese tax treaties that were concluded in different periods of time (e.g., 1980s-1990s; 2000-
2015; post 2015) with different types of countries (e.g. OECD members, BRICS and developing countries)
(“treaty practices”);
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c) compare Chinese treaty practices with the relevant provisions of the OECD Model Convention; and
d) to the extent applicable, discuss China’s position in BEPS 1.0 and BEPS 2.0 (Pillar One and Pillar Two) in
regard to the chosen topic; and
e) analyze and assess China’s position on the chosen topic and its convergence or divergence from the OECD
approach (as reflected in the OECD Model and Commentaries) and the standards or practices created through
BEPS 1.0 and to be created through BEPS 2.0.
Deviations from the above are acceptable if the subject matter warrants such deviations

Sample Solution