完善受控外国企业税制 加强受控外国企业管理——《特别纳税调整实施办法(试行)》之“受控外国企业管理”

Improving the Tax System concerning the Controlled Foreign Companies and Enhancing the Management towards Them: An Interpretation of 'CFC Management'in the Implementation Rules for Special Tax Adjustments (Interim)

随着我国对外资本输出的增加,以受控外国企业为载体的避税行为日趋严重。本文在充分介绍受控外国企业税制体系和解读受控外国企业税制的基础上,就受控外国企业的相关涉税问题做了进一步的探讨。

Along with the growth of overseas investments by domestic enterprises, the issue of tax avoidance through the controlled foreign companies （CFCs） has become more and more serious. Based on a comprehensive introduction and interpretation of the tax system concerning CFCs, this paper makes a further discussion on some tax issues related to CFCs.