The Puzzle: China’s Covered Tax Agreements Seem Unchanged after the MLI from Taxpayers’ Perspective?

This article uses the rule-standard spectrum theory to analyse the puzzle of why taxpayers may have the impression that China’s covered tax agreements (CTAs) seem unchanged after theMultilateral Instrument (MLI) despite the country having devoted enormous efforts to implementing it. This study finds that most of the changes in China’s CTAs through the MLI are standard-based provisions while it is willing to unilaterally and bilaterally embrace certain rule-based MLI provisions. The characteristics of China’s model in adopting the MLI, the possible reasons behind the model, and the implications for taxpayers are further explored. MLI, China’s CTAs, standard-based changes, rule-based changes, administrative-led legislative model, multi-dimensional tax policies, compliance cost, certainty and uncertainty, cooperation