我国境外所得抵免税制的优化取向

The Optimum Orientation of China's Foreign Income Tax System

近年来,属地征税制度已经成为解决跨国投资所得双重征税的一种国际趋势。美国税改引入属地税制,这对主要以借鉴美国抵免税制课征境外所得的我国,提出了新的课题。通过对美国税改进行简要剖析,结合我国经济发展与税制改革现状,本文建议我国暂不宜转型为属地税制,而应尽快优化现行抵免税制。

In recent years, the territorial taxation system has become a global trend in solving the double taxation of cross- border investment income. The newly introduction of the territorial taxation system in the US tax reform has raised new issues in China, which taxes foreign income based on the references to the tax credit system of the United States. By a brief analysis of the US tax reform, and combined with the current stage of China＇s economic development and tax reform, the paper suggests that China shall not be transformed into the territorial tax system at present and shall optimize the current tax credit system as soon as possible.