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跨国并购已成为我国对外投资的重要模式,但跨国并购涉及的复杂税收问题加大了企业并购风险。本文按经济发展状况、地域分布选取了10余个国家分别从免税并购成立要件及其税收待遇、目标公司税收属性结转利用、并购债务融资税收限制、跨国并购反避税规定等角度对比研究了其并购税制。在此基础上进一步分析了跨国并购可能带来的四类税收风险并提出风险应对策略。
Cross-border M & A has become an important model of China’s foreign investment, but the complex tax issues involved in cross-border M & A increase the risk of mergers and acquisitions. Based on the economic development and geographical distribution, more than 10 countries choose the conditions of tax-free mergers and acquisitions, the tax treatment, the carry-over of the taxation properties of the target companies, the tax restrictions on debt financing of mergers and acquisitions and the anti-avoidance provisions of cross-border M & A M & A tax system. On the basis of this, we further analyze four types of tax risks that may arise from cross-border M & A and propose strategies to deal with the risks.