关于企业所得税框架下总分机构汇总纳税的思考

Some Thoughts on Tax Consolidation of Head Office and Branches within the Framework of the EIT Law

《企业所得税法》实施两年多来,由于汇总纳税相关政策尚未明确,部分政策在一定程度上欠合理,加之总分机构所在地税务机关存在"责权利"不匹配等问题,使总分机构企业及总分机构所在地主管税务机关面临诸多税收执行的困惑。本文从政策和征管的层面提出问题,并就解决这些问题提出自己的建议。

It has been more than two years since the Enterprise Income Tax Law came into force.However,there are still some unclear policies on tax consolidation of head office and branches and even some policies are not rational to some extent.In addition,due to segmented administration and disproportionate ＇accountabilities,powers and benefits＇,many tax authorities which are responsible for administering head office and branches are faced with problems in practice.This paper analyzes some of these problems from both policy and implementation perspectives and presents its own solutions.