Research On The Taxation System Of Controlled Foreign Companies In My Country

Economic globalization is the most important characteristic of the times in the world today,and as the economy becomes increasingly global,multinational corporations also play a pivotal role in the development of economic globalization.However,along with the booming development of foreign direct investment by multinational corporations,the amount of tax avoidance caused by the use of tax-exempt base companies to transfer profits is also alarming.In order to combat this phenomenon of eroding the tax base and transferring profits,the US Congress passed the taxation system for controlled foreign companies in 1962,and various countries have also introduced legislation.At present,in the new round of international tax reform,countries around the world are paying more attention to the issue of multinational corporations eroding tax bases and transferring profits through controlled foreign companies.The G20 finance ministers called on the OECD to formulate an action plan for the coordination of countries.Comprehensive response to tax base erosion and profit transfer issues.For the first time in this year,China revised the new corporate income tax in 2007 to introduce the tax system of controlled foreign companies.In 2009,it gave a relatively complete explanation.At this point,the controlled foreign company tax system is formally enacted in China.However,with the expansion of China’s foreign direct investment,the characteristics and the increasing number of multinational corporations,China’s current controlled foreign company tax system has been difficult to cope with the current tax environment.This paper focuses on the existing problems of the tax system of controlled foreign companies in China,briefly introduces the basic situation of the tax system of controlled foreign companies,analyzes the impact of China’s overseas investment on China’s tax system,and secondly introduces the current tax in China.And combined with the investigated cases to analyze the existing problems of the tax system of controlled foreign companies in China,and believe that the determination of the applicable tax system of controlled foreign companies in China,the expansion of the scope of taxpayers,the identification of "reasonable business needs",and the recognition of income The six aspects of rationality,exemption clauses and priority to tax treaties need to be further revised and improved.Through the comparative study of the tax system contents of controlled foreign companies in the United States and the United States and the analysis of typical cases,it provides reference for improving the tax system of controlled foreign companies in China.Finally,combined with the analysis of the tax system of China’s controlled foreign companies and the reference of the United Kingdom and the United States,it gives suggestions from three aspects: the object of the controlled foreign company tax system,the content of the tax system,and the supporting measures: the transparent entity Introduce the applicable types of controlled foreign companies,introduce presumptive holding rules in equity control,and add taxpayers of individuals holding controlled foreign companies;the method of confirming income should be transitioned to a fair trading law,and the corresponding exemption clauses should be amended and added.Quantify the requirements for reasonable business operations and introduce the US commercial purpose and economic substance test,establish a tax declaration system for the controlled foreign companies and the inversion of the burden of proof;strengthen the professionalization of anti-tax avoidance work,the cultivation of professional talents and information sharing.