减税降费背景下我国避免对外投资双重征税政策研究

Double Taxation Relief:Analysis and Implication for China

对外开放是基本国策,减税降费是近些年我国应对经济下行压力所采取的重要举措。在此背景下,如何更好解决对外投资中所面临的重复征税问题尤为重要。跨国投资征税实践中常用的两种避免双重征税的方法包括抵免法与免税法。研究结果表明:相较于抵免法,免税法能够更加有效地促进对外投资和降低税收的征管成本,并且不会以牺牲过多的税收收入作为代价。结合中国的对外投资情况计算得出,如果我国从抵免法转为免税法,对外直接投资所取得的股息收入的税收负担将从25.4%降低到14%;对63个"一带一路"沿线国家而言,这个数字将从26.9%下降到22.7%。

Opening-up is the basic state policy,and slashing tax and fee is the important measure China has adopted to tackle the pressure caused by economic downturn.In this context,how to relieve double taxation for foreign investment is worth researching.This study analyzes the advantages and disadvantages of the two mostly commonly used methods for double taxation relief and provides relevant economic studies.We find that,compared to the credit method,the exemption method offers stronger incentives to outward investment and it has lower administrative costs.It may not sacrifice much tax revenue as the credit method.Further,we calculate that the FDI weighted tax liability on the dividend income decreases from 25.4 percent to 14 percent as China switches from the credit method to the exemption method based on the statutory tax rates of the ten largest jurisdictions having Chinese outward investment.We conduct a similar study for the 63 B&R countries as well and find that this number drops from 26.9 percent to 22.7 percent.