我国基金税制布局中的问题与模式选择

The Problems and Option for the Arrangement of Funding-Taxation in China

基金是具有信托属性的投资领域容易发生多环节重复征税，依据基金“集合投资中介”和“信托经营实体”的双重特点，应该通过合理的制度安排消除基金投资的多重征税，使其同信托活动和直接证券投资税负衔接。我国现行基金税制缺乏整体布局的协调性，需要借鉴国际惯例加以调整，做到既能与一般信托税制协调，又具有不同的特殊待遇。

Fund-investing is a kind of financial investment which has an attribute of trust and tends to multiply taxation, Fund trusting has a dual-properly, which is ＂collective investment＂ and ＂management entity of trust＂. According to that, proper arrangement of taxation can eliminate the problem of multiple-taxation of tund investing and also make good links with trust investment and stock investment. The now-applying taxation arrangement of the fund investing in China lacks the coordinateness of entirely, which needs the adjustment of learning from international convention so that it can be coordinating with the ordinary trust taxation.