Analysis of Inter-Regional Tax Cooperation Rule Alignment in the Greater Bay Area

Abstract

The central government has incorporated the development of the Greater Bay Area into the broader national development strategy. Improving the inter-regional tax cooperation system among the mainland, Hong Kong, and Macao is a crucial component of advancing judicial integration in the Greater Bay Area. This paper analyzes existing cases by interpreting key documents of central and local government, integrating the latest academic research, and examining the current tax cooperation arrangements with taxpayer information sharing mechanisms in the Greater Bay Area. It identifies challenges within the existing system: a final tax dispute resolution mechanism has yet to be established, a coordinated mechanism among the three regions' tax authorities is yet to be formed, and differences persist in tax procedures across the three regions. Finally, drawing on comparative law perspectives, this paper reviews existing inter-regional tax cooperation models in other countries. Considering the Greater Bay Area's unique circumstances, it proposes selectively adapting international experiences to enhance the tax cooperation framework. Key recommendations include establishing a unified tax filing system, promoting coordination among tax authorities in the three regions, and appropriately adopting the Mutual Agreement Procedure (MAP) arbitration process. By examining the challenges in inter-regional tax rule coordination within the Greater Bay Area, this paper aims to provide new perspectives and solutions for advancing judicial integration in the region.