我国非居民企业税源管理中的风险与应对

Risks in Tax Source Administration of Non-resident Enterprises in China and Their Countermeasures

非居民企业税源是跨境税源的重要组成部分,既包括非居民企业在中国境内设立机构、场所取得的所得,也包括未设立机构、场所但有来源于中国境内的所得。本文针对非居民企业税源的不同类型,分析了其存在的税收风险,并提出应对办法。

Non-resident tax source is an important part of cross-border tax source, which includes the income derived from establishments or venues set up by non-resident enterprises in China, and also the in- come derived from China but having no establishments or venues in China. Based on different types of non- resident tax source, this paper makes an analysis on their tax risks and puts forward some countermeasures.