进一步完善我国受控外国企业税制

Further Improving the Tax System of Controlled Foreign Companies in China

我国受控外国企业税制的设计参考了欧美发达国家受控外国企业税制的内容,与国际通行的做法基本一致。然而,我国受控外国企业税制的规定还较为原则,虽然国家税务总局已经出台有关文件予以补充和细化,但在受控外国企业税制的适用地域和适用的纳税人、受控外国企业税制与税收协定的关系、受控外国公司归宿所得的计算等方面,仍然需要进一步完善。

Reference was made from the western developed countries in the design of tax system concerning the controlled foreign companies in China, which is in accordance with general international principle. However, the tax system concerning CFC is still far from perfect, although the State Administration of Taxation has issued some regulations for supplement and elaboration, still many aspects like the range of regions and taxpayers applicable to CFC regimes, the relationship between CFC regimes and tax treaties,the calculation of CFC＇s attributable income, shoulld be improved.