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2009年1月8日,经过近一年的意见征求,国家税务总局《特别纳税调整实施办法(试行)》(以下简称《办法》)正式出台。《办法》的发布和实施,标志着经过数十年努力,我国终于构建起较为完备的反避税体系,反避税管理工作步入科学规范、全面提升质量的新阶段。经济全球化进程的加快以及跨国公司的发展,使税源国际化的趋势日益明显,在这一趋势下,各国都高度关注跨国公司避税问题,反避税已成为各国税收征管的重要内容。如何从完善立法和加强管理两方面采取措施,防止本国税收转移,维护本国税收权益,已成为各国税务当局面临的主要课题之一。正是在这样的大背景下,《办法》应运而生。为了帮助读者更好地理解《办法》的精神,帮助纳税人更好地履行自己的义务,维护自己的权利,本刊延请长期从事反避税工作和参与《办法》制订的相关人士从多角度、多层次对《办法》进行权威解读。《〈特别纳税调整实施办法(试行)〉出台的背景及意义》一文中,作者介绍了我国反避税工作的历史和现状,《办法》出台的背景和意义,以及纳税人如何积极应对,降低可能面临的反避税审计风险。在《〈特别纳税调整实施办法(试行)〉赋予纳税人的权利义务》一文中,普华永道会计师事务所合伙人庄子男先生通过归纳总结《办法》赋予纳税人的权利义务,为纳税人如何应对提供了参考措施。
On January 8, 2009, after nearly a year’s solicitation of opinions, the “Implementation Measures for Special Tax Adjustments (Trial)” (the “Measures”) of the State Administration of Taxation was formally promulgated. The promulgation and implementation of the Measures indicate that after decades of efforts, our country has finally built a relatively complete anti-avoidance system and stepped up a scientific and standardized anti-tax-avoidance work to comprehensively improve the quality of the new phase. With the acceleration of economic globalization and the development of transnational corporations, the internationalization of tax sources has become increasingly evident. Under this trend, all countries are highly concerned about the issue of tax avoidance by multinational corporations. Anti-avoidance has become an important part of tax collection and administration in various countries. How to take measures to improve the legislation and strengthen the management of both sides to prevent the tax transfer in our country and safeguard the taxation rights and interests of our country has become one of the major topics that the tax authorities in various countries are facing. It is against this background that “methods” came into being. In order to help readers better understand the spirit of the “measures” and help taxpayers to better fulfill their obligations and safeguard their own rights, this journal defers to relevant persons who have been engaged in the anti-tax avoidance work and participating in the formulation of “measures” for a long time from a multi-angle, Multi-level “method” for authoritative interpretation. In his article “Background and Significance of the Implementation of Special Tax Adjustment (Trial)> Introduction and Significance”, the author introduced the history and current situation of anti-tax avoidance work in our country, the background and significance of the introduction of “Measures”, and how taxpayers can actively respond and reduce the possibility of Anti-tax avoidance audit risk faced. In the article entitled “Special Tax Adjustment Implementation Measures (Pilot)> Assigning Taxpayers Rights and Obligations”, Mr. Zhuangzi Nan, Partner of PricewaterhouseCoopers, summarized and summarized the rights and obligations conferred on taxpayers by the “Measures” and provided taxpayers How to deal with the provision of reference measures.