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随着改革开放的进程,中国日益介入全球经济一体化体系,众多外资企业参与投资中国,与之对应,中国税务机关的反避税压力与日俱增。出于保障国家税收主权的需要,中国税收执法实践,越来越多地运用税法透视原理来加强税收征管,以堵塞税收漏洞。本文试以非居民企业股权转让为视角,简述近年来中国税法实践中的透视案例①,并试图对其简要评析,以为抛砖
With the process of reform and opening up, China is increasingly involved in the global economic integration system. Many foreign-funded enterprises are involved in investing in China. Correspondingly, the tax authorities in China are facing increasing pressure on anti-tax avoidance. For the sake of ensuring the tax sovereignty of the country, tax law enforcement practice in China increasingly uses the principle of tax law to strengthen tax collection and administration so as to plug the tax loopholes. This article attempts to non-resident enterprises from the perspective of equity transfer, briefing on China’s tax practice in recent years, the case of perspective ①, and try to briefly comment on it, that start throwing brick