Research On The Problems And Countermeasures Of The System Of Withholding The Source Of Income Tax Of Non-resident Enterprises Under The Background Of Digital Economy

Through the oretical analysis of the digital economy and non-resident corporate income tax administration system,the theoretical support of the system and the management level is sorted out.In the process of theoretical analysis,combined with the status quo of China,the income tax source of non-resident enterprises in the digital economy background is found.There are many problems in the payment system,both in the system and in the tax collection and management.The system level includes difficulty in determining the object of tax collection,difficulty in determining the tax exemption limit,difficulty in determining the permanent establishment,whether the withholding agent can be excused from the unclear obligation of withholding in special circumstances,and whether the non-resident enterprise can be withheld and withheld.The obligor is not clear and other issues;the tax collection and management level includes difficulties in tax registration,incomplete taxation information,and imperfect implementation rules of the policy system.According to the above-mentioned system and the issue of tax collection and management,the author selects three representative cases for specific analysis to derive the international experience that can be used for reference,in order to get useful enlightenment from the international frontier theory and advanced experience,and to the digital economic background of China.The construction and improvement of the non-resident corporate income tax source deduction system will help.For example,from the perspective of the definition of income in the digital economy,whether China ' s withholding agent as payer should fulfill the consideration of withholding and paying obligations;from the perspective of transfer pricing,analyze the withholding agent in the context of digital economy The size of the tax base that can be withheld.In the end,the paper puts forward the countermeasures and suggestions for the system of collecting and paying income tax sources,such as increasing the rules of virtual permanent establishment,implementing double taxation jurisdiction,and improving the non-contributory enterprise's unpaid tax collection system from the perspective of system and tax collection and management.