Research On Tex System Of Controlled Foreign Companies In China

At present,China is in the process of economic transformation from "imported" mode of economic development to "going out" mode of Chinese enterprises.A large number of "going out" enterprises in China have developed rapidly,and have invested or produced activities all over the world with the support of policies such as "one belt and one road".However,such development has also brought about the problem of tax base erosion and profit transfer caused by different tax burden levels between countries and regions.In order to effectively prevent such tax base erosion and profit transfer,promote the healthy and orderly development of multinational group companies and make them more standardized,it is urgent to further study the related issues of controlled foreign subsidiaries,it can be said that the corresponding tax system in our country is still a preliminary exploratory stage,in the current new era.With the tide of tax reduction and the changing international situation,the study of CFC tax system in China has become more and more necessary.Controlled foreign company rules are rules to prevent resident shareholders who have control of foreign subsidiaries from using controlled foreign subsidiaries for profit transfer and long-term tax deferral.This paper mainly adopts comparative analysis and case study methods,from the aspects of "control","reasonable business purpose","CFC income","exemption clause",declaration rules and other aspects,combined with BEPS report and national practice,in view of the current legislative and practical situation in China,based on the case study of two controlled foreign enterprises in China,the advantages and disadvantages as well as the existing policy and collection and management problems are analyzed,and suggestions for improvement are put forward.Based on this,the article will be divided into six parts for research: The first part is an introduction,which mainly introduces the background of the topic,the significance of the research,and the literature review at home and abroad.The second part mainly introduces the background of the emergence of controlled foreigncompanies,the current situation of China's foreign investment and the definition of related concepts of controlled foreign companies.The third part introduces two cases selected in this paper,and analyses the existing problems of the tax system of controlled foreign companies in China by summarizing the controversial points.The fourth part is to analyze the existing problems and shortcomings of the tax system of controlled foreign companies in China on the basis of combing the relevant legislation of controlled foreign companies in China.The fifth part is the reference and summary of advanced experience of foreign controlled companies in tax system.The sixth part is to improve the tax system of controlled foreign companies in China.Based on the latest international situation and the background of China's own tax system reform,this paper puts forward corresponding suggestions,which not only ensure the absence of its own jurisdiction,but also promote the healthy development of China's "going out" enterprises.