Research On Income Tax Of Overseas Investment

In 1990s,China entering a new stage of reform and opening up, the CPC Central Committee and the government timely put forward the "going global" development strategy to promote the launching of China's enterprises in international trade, so that our country gradually introduced to the capital input from the export of capital.In 2009, the direct foreign investments in China were total 56.5 billion dollars, ranking fifth in the world. In the "Government Work Report 2010," Premier Wen Jiabao continues to emphasize the followings:Accelerating the implementation of "going out" strategy, encouraging the industry demand in foreign markets to transfer capacity outside orderly, supporting qualified enterprises to carry out overseas mergers and acquisitions, offshore resources to deepen mutually beneficial cooperation, increase the quality of foreign contracted projects and labor service cooperation.further simplifying approval procedures, implementing the autonomy of corporate foreign investment, the enterprises who is "Going out" has to operate according to the law, to avoid risks, to prevent vicious competition and to safeguard the country's overall interests and the good image.In the form of our gradual expansion of overseas investment, China's tax policy is still unable to adapt to the rapid development of international trade trends, there being many problems. The problems encountering in the process of overseas investment are insurmountable by China's present tax law, which severely hamper the operations of multinational enterprises. Therefore, in the face of the tide of economic globalization and integration, it is a theoretical and practical problem that how to learn from the advanced experience of foreign countries to develop and improve our corporate income tax policy; to adjust our way of foreign credit; to establish a multi-angle, three-dimensional system of tax incentives; to enrich our tax treaty system; to guide and promote foreign investment and operation of enterprises into the sound track, to guide and support multinational operating of our enterprises in the use of tax policy,and to enhance our business competitiveness in the international market, is a theoretical and practical significance of the major problems.This article seeks to research on the corporate income tax policy of overseas investment on the basis of the existing literature. It is to propose the proposals of relevant tax policy in the process of national industrial structural adjustment, through drawing on the experience of advanced countries in the world and basing on China's basic national conditions.The introduction briefly introduces the research background and significance, and does a foundation narrative for the structure of the main framework of this paper, based on the domestic research results.The first part is the analysis for the need of overseas investment enterprises. Comparative advantage theory is the basis of our theory of foreign investments. Firstly, it explains the Origin, content development and major characteristics of the theory of comparative advantage. Secondly, overseas investment and operation of enterprises need to be addressed on the basic of the theory of comparative advantage, namely, the need for their own development, the need for national economic development, the need for global economic integration to be described. Finally, the status and the main problems are described of foreign investment and management of corporate.The second part is the analysis for the corporate income tax impact on foreign investment and operation. Corporate tax has an important impact on foreign investment in business enterprises. Firstly, it analyzes the corporate tax impacts on the company from two aspects of the vested interests of enterprises and the business risk of the company. Then, it analyzes the capital export neutral tax system, capital input neutral tax system and the national neutral tax system from Comparative aspects of tax business income from overseas Investment and it introduces the corresponding the methods to eliminate international double taxation that are suitable for three kinds of tax system.The third part is the analysis for the income tax policy of current foreign investment and management. This section focuses on the tax policy in China's business income tax on foreign investment, highlighting the regulations of investment management since the implementation of the new Enterprise Income Tax Law. Then, it analyzes in-depth the problems with our current income tax policy.The fourth part mainly describes the world advanced experience of foreign investment policy and specific measures. It strives to find suitable ways and means of foreign investment and operation through the list and analysis of foreign investment of developed and developing countries.The fifth part is to improve the proposals for the income tax policy of foreign investment. Firstly, it introduces the principles which should be guided by, taking into account the needs of international trade, industrial structure adjustment, etc., to improve China's enterprise income tax policies. Finally, this paper proposes the proposals for the promotion of overseas investment enterprises operating in the tax policy.