离岸公司避税的法律规制-法律专业论文.docxVIP

AbstractFrom Abstract From the middle of the’last century’1ater,the offshore jurisdictions flourish．’ Offshore juri sdi ctions，the most prominent feature i that the pol icy of the company registration procedure is simple， and has almost restrictions capital flows and it hard imposes any‘tax the business activities that not conducted in the registered areas．。Also it is of good confidentialit．y．Offshore companies limited liability companies and王imited liability corporations engaged in the business outside the offshore jurisdiction，that established in the offshore jurisdiction by Non—local investors，in accordance with the specialized offshore company law special provisions of Company Law in general． The policy of Offshore jurisdictions created it tax haven in the field of international taxation．Almost all aspects of tax transferring by the tax subject tax object involved in offshore tax avoidance．It is collection of the misuse of tax agreements，transfer．pricing and other means。So it．is comprehensive tax avoidance mode．Regardless of the offshore company controlled by what kind of concrete form, setting up offshore companies in the offshore jurisdictions，carrying intermediary business through offshore companies， in the of intermediary business the extensive of transfer pricing。capital di lution，the abuse of tax agreements and such to min-imize the tax burden，the basic objective of maximizing the return tax avoidance model is universally applicable．Common modes in offshore tax avoidance by offshore companies holding company model，offshore business(intermediary trading company)model，an offshore financial companies mode． In this paper，a legal identify made to the offshore company tax avoidance，and the principle of off—’shore companies tax avoidance introduced—‘substance form principle．On basis above，in accordance with OECD recommendations，the to regulate the offshore companies tax avoidance fall into two categories：Regulation of unilateral and multilateral collab