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从两岸双重不征税产生的原因入手,进而分析其理论根源,最后分析如何在将来的两岸税收安排中避免双重不征税。转让定价调整通常被认为主要针对所得税,其规则设计也大多以所得税为基础。
Beginning with the reasons for the double non-taxation of the two sides of the Taiwan Strait, and then analyze its theoretical roots, and finally analyze how to avoid double non-taxation in future cross-Strait tax arrangements. Transfer pricing adjustments are generally considered mainly for income tax and most of the rules are based on income tax.