中国走出去企业的现状及如何完善我国反避税政策选择总结报告.ppt

Under the new domestic and international economic circumstances, some taxpayers first choose to dodge tax as a result of the strengthening investigation and punishment on tax evasion. As for international tax avoidance, the countries concerned generally only through the improvement of tax laws or amendments to plug loopholes in the law. But we ignore the importance of punishment. Since international tax avoidance involves at least two countries, it is far from enough that countries has no exchange of information but just improve the tax law and tax system further. Special Tax Haven Provisions Nonresidents take tax benefits without substantial activities No exchange information with others No-transparent way Of providing tax benefits Tax Haven Tax benefit: low tax rate ,less type of tax, a tax holiday or other tax incentive, and a tax-deductible loss Main tax havens : the Bahamas, Monaco, the channel islands, Bermuda 陈逸婷 0121199 The negative impact of tax havens Make the international investors obtain improper benefit Eroded the tax benefits of relevant capital exporters Disturbing the order of the fair tax. Abetting the money laundering and corruption activities. Special Tax Haven Provisions 陈逸婷 0121199 Special Tax Haven Provisions Unilateral countermeasures: including CFC rules, foreign investment fund rules, transparent tax rulings, and restrictions on participation exemptions Countermeasures involving tax treaties: including increased administrative cooperation and exchange of information with respect to harmful tax practices Countermeasures involving international cooperation 陈逸婷 0121199 Thin Capitalization Rule The company, which is funded by multinational companies use the method of loans rather than offering, in order to increase the cost and reduce taxable income. As a fixed ratio Average the ratio in a particular industrial Definition: Computation of a debt : equity ratio 陈逸婷 0121199 Thin Capitalization Rule The more than equity capi