Research On Anti-tax Avoidance Of Hybrid Mismatch Of Multinational Corporations In BEPS

In recent years,with the integration of the world economy and the development of digital economy,the tax avoidance of multinational corporations has gradually increased.On the one hand,the existence of transnational corporations allows capital to go beyond the boundaries of national borders and can flow globally.It can promote the capital investment to the place with real investment value to realize the optimal allocation of resources.On the other hand,economic globalization also provides an opportunity for transnational corporations to implement global tax avoidance.In order to obtain greater benefits in the fierce international competition,these multinational corporations use various taxation arrangements to carry out tax planning,which has led to serious erosion of tax bases in various countries,thus forming a tax base erosion and profit transfer(BEPS).One of the methods of mixing mismatches as a tax avoidance for multinational companies is an important method for international tax avoidance.Mixed misalignment arrangements are multinational corporations that use two or more tax jurisdictions to make arrangements for differences in the tax treatment of the same financial entity or carrier in order to achieve double non-taxation or long-term deferred tax payment purposes.At present,the mixed misallocation arrangement has caused great threats to the tax base and tax security of many countries,and has caused serious tax losses for various countries.This article uses literature research method,case analysis method and comparative analysis method to conduct research.Firstly,through the introduction of the relevant research background and the research of international tax avoidance and mixed mismatches both at home and abroad,this paper proposes the purpose of this study and the starting point of the research problem.Secondly,the relevant theories and operating mechanisms of the mixed mismatch arrangement are introduced.It is pointed out that mixed misfits mainly include mixed financial instruments,hybrid payment,reverse mixture and input type mismatch,and the tax avoidance effect of various types Explain.Then we introduce China's anti-tax avoidance and deal with the status quo of the mixed misalignment arrangement and its shortcomings,and select a more typical mixed misalignment program to analyze relevant cases.It points out the operating mechanism of the mixed mismatch arrangement in practice and the great harm to the tax security of all countries in the world,and then puts forward relevant suggestions on how to deal with these mismatch arrangements.Based on an analysis of the main countermeasures taken by other countries when dealing with related issues,the corresponding countermeasures for dealing with mixed financial instruments,hybrid payments,reverse-mixtures,and input-type mismatch arrangements were summarized and proposed.Inspiration.Finally,based on our country'sactual conditions,we must draw lessons from foreign experiences and propose corresponding measures for how to deal with the tax harms caused by these types of mixed misalignment arrangements.