According to the fact that Baori Company is a Sino-Japanese cooperative enterprise, it can be concluded that it is a Japanese legal person.

according to the principle of tax residents' jurisdiction (another principle is the principle of source tax jurisdiction, which is mainly aimed at transnational taxpayers), that is, the tax power exercised by the state according to the connecting factor of taxpayers' tax residence in their own country. There are three criteria for whether a legal person is a resident taxpayer: the place where the legal person is registered, the place where the actual management and control center is located, and the place where the head office is located. China adopts the second standard, that is, the location of actual management and control center, which mainly depends on the location of shareholders' meeting and board of directors. According to the case, the actual management and control center of Baori Company is in China. Therefore, China has obtained the tax jurisdiction over Baori Company.

to sum up, baori company's claim cannot be established. China Shenzhen Taxation Bureau has the right to ask Baori Company to pay taxes. The Shenzhen Intermediate People's Court shall reject the plaintiff's claim according to law.

the question "oh ~ ~ PS" that I analyzed bit by bit has something to do with international economic law, because some scholars classify the contents of international tax law into international economic law.