A Research On The Perfection Of The Rules Of Controlled Foreign Corporations In China

In recent years,international trade has become more frequent and multinational companies continue to rise,the international tax field also entered a new era.Combating tax base erosion and profit transfer has become the focus of international tax cooperation.In order to obtain tax benefits,multinational companies in China use a variety of means to carry out tax planning.The use of controlled foreign companies for tax avoidance has become a common means.Therefore,in order to protect the tax revenue,standardize corporate behavior,create a good international business environment in international companies,it is imperative to improve the CFC rules of our country.Based on the experience of typical countries and the results of the Third Action Plan of BEPS,this article hopes to make some suggestions on how to perfect the CFC rules in our country.First of all,the article elaborates the background,significance and purpose of the study of CFC rules in our country.In the background,the basic concepts and main contents of the CFC rules are expounded.In the significance,the positive effects of the CFC rules on the international taxation of our country are discussed.Then the article analyzes the theories of CFC rules and gives depth interpretation of Substance over form principle,Arm’s length principle and Benefits principle.And the article carries out a comprehensive and systemati c analysis of the main elements of the CFC rules.Then,through the introduction of the current situation of the CFC rules in our country,the article summarizes existing problems of the CFC rules in our country.And the article get the enlightenment through analyzing the research results of BEPS third action plan and the advanced experience of typical countries.Finally,the article gives the idea of perfecting the CFC rules from micro to macro,from concrete policy to overall framework.The article hopes to give a reasonable and concrete proposal to the CFC rules in China.However,in order to give full play to the role of CFC rules,it requires close cooperation between countries.Ensuring the validity of policy connection is a better way to combat tax avoidance.Without the once and for all policy,the CFC rules in our country should be constantly improved according to the actual situation.