QFII内地股票投资--免税的大餐？

Mainland Stock Investments of QFII: Is It a Duty-free Lunch?

合格境外机构投资者(Qualified Foreign Institutional Investors,以下简称"QFII")在内地股票投资的收益在国内法上负有向内地政府缴纳10%预提所得税的义务,但由于一部分中外税收协定对此的特殊规定以及公开证券市场交易的特殊性等原因,此类业务在事实上一直享受着"免税大餐"。本文建议内地税务机关委托内地资金托管银行代征QFII在内地的应纳税款。

Qualified Foreign Institutional Investors （hereinafter referred to as ＂QFII＂） shall pay withholding income tax at 10% of the income from stock investments in China's Mainland as stated in relevant domestic laws, yet in practice they have not paid that tax due to some special rules in tax treaties between China and some foreign countries as well as the particularity of public securities business. This paper suggests that tax bureaus in China's Mainland shall authorize capital trustee banks to collect the withholding income tax instead.