The double taxation treaty and local taxation law will be applied when we tax the transnational incomes of the partnership. Because of different regulations in states， different tax treatments to partnership will be adopted which result in some conflicts about the characterization of the incomes and double or no taxation. Therefore， we should study the resident qualification of the partnership， business profits and the special incomes by considering the double tax treaty and the local law of the contracting states in order to apply the double taxation treaty correctly and avoid the double and no taxation.