Research On Tax Risks Of W Company's Permanent Establishment In China

Under the trend of economic globalization,with the progress of science and technology,the industrial capital,scientific and technological achievements,human resources,and many other factors of production in the global scope rapid configuration to earn excess profit as possible,so the economic globalization for multinational enterprise or multinational business taxation management put forward higher requirements.In China,since 2008,non-resident enterprise income tax revenue has increased year by year,and the proportion of tax revenue has been increasing.By 2017,China's non-resident tax revenue reaches 174.3 billion yuan.So the independent declare and pay and source of non-resident enterprise income tax withholding management also becomes the focus of the tax,a non-resident enterprise tax management also became under the background of economic globalization national tax authorities are focus on the field.In this background,this article through the case analysis,with registered in Hong Kong W company as the research object,through W company in our country may 'be involved in the standing body of tax risk,and put forward targeted Suggestions,on the one hand can prevent standing body for W company tax risk put forward feasible Suggestions,on the other hand can also for other non-resident enterprises play a certain reference significance.First of all,this paper first on the international tax treaty and the domestic tax laws,regulations and policies in the standing body of the relevant provisions of the comb and the corresponding interpretation,combed the 2009-2016,the six important normative documents enacted by the legislature of the development of case analysis provides the policy basis for this article,Again,from the practice of tax in our country,the selection of the universal representative W company as a case,the applicable policy combined with concrete practice,of W company business activity in our country has carried on the detailed introduction,clear,fully shows the W company industry background and the scope of business,organization structure and business arrangements in China,and under the background of BEPS of W company business in our country may be involved in the standing body of tax risk identification;Finally,it provides the operation guide for W company to prevent the tax risks of the permanent institution.