浅谈美国税收协定中的饶让抵免政策

On Tax Sparing Policy in Tax Treaties Concluded by the United States

经济合作与发展组织较为发达的成员国中,只有美国坚决不接受饶让抵免政策。本文将探究美国持此立场的原因,反映美国国内支持饶让抵免的观点,并结合美国2017年税改引入的参股免税制度,对其重新审视饶让抵免的必要性及对我国的启示进行思考。

Among the more developed member countries of the Organization for Economic Co-operation and Development(OECD), only the United States resolutely refuses to accept tax sparing in the tax treaties it has ratified. This paper explores the reasons why the US holds such a position toward tax sparing and records a supportive attitude to this policy within the US. Taking into consideration the participation exemption introduced by the 2017 tax reform of the US, the necessity for the US to reconsider tax sparing policy and what China can learn from the experience of the US have been contemplated.