| The emergence and development of value chain theory is driven by the process of economic integration.The value chain analysis emphasizes the integrity of the profit creation process,and requires the related transactions of all parties to adopt all information collection and quantitative comparisons,jumping out of the previous framework of starting from a single transaction behavior,focusing on the analysis of the overall transaction model,and paying attention to the links of each link in the value chain.Feature.With the rapid development of the digital economy and the accelerating process of world economic integration,cross-border enterprises have increasingly become an important driving force for global economic development.When facing complex business environments such as different cultures and systems,cross-border enterprises need to expand the scope of management and improve management levels to rationally allocate strategic resources in various regions so as to maintain their own advantages.However,with the continuous diversification and complexity of value chain activities,the tax avoidance methods of cross-border enterprises have also become diverse.Traditional methods such as transfer pricing,related party transactions,and tax avoidance in tax havens can no longer meet their needs.Cross-border companies have begun to adopt more new comprehensive tax avoidance methods,such as value chain function transfer,mixed mismatch arrangements,and artificial avoidance of permanent establishments.Applying value chain theory to cross-border anti-tax avoidance collection and management can effectively improve the efficiency of anti-tax avoidance work in the context of the digital economy.The construction of our country’s anti-tax avoidance system started relatively late.In recent years,based on the background of the times,my country has paid more attention to the formulation and implementation of anti-tax avoidance laws and regulations.coming impact.In particular,the international tax avoidance methods of cross-border enterprises are becoming more and more hidden and complicated,and many problems have been exposed in my country’s anti-tax avoidance system.At present,most of the policies and regulations on tax avoidance of cross-border enterprises issued by the world and in my country focus on individual transaction behaviors.The policy is highly directional and targeted,and it is difficult to apply the comprehensive tax avoidance model derived from the development of the digital economy.The analysis based on the value chain theory jumps out of the traditional single tax avoidance behavior.From the perspective of the multinational group as a whole,it pays attention to the contribution of each link in the group’s value chain.It can be applied to the comprehensive tax avoidance model and effectively prevent and control tax avoidance in the digital economy.Based on the value chain theory,this paper takes the international tax avoidance and anti-tax avoidance environment under the digital economy as the research background,and takes cross-border enterprises as the research object.Firstly,the traditional tax avoidance behavior of cross-border enterprises and the new tax avoidance model under the background of digital economy are analyzed in detail;secondly,the current situation of relevant anti-tax avoidance measures in China is systematically sorted out,and the existing problems are found;then,Dell Ireland-Dell Spain cross-border tax avoidance Taking this case as an example,analyze its means of tax avoidance,tax avoidance motivation and the whole process of the trial and final characterization of the case by the tax authorities of both countries,summarize the international anti-tax avoidance collection and management issues exposed in the case and draw case inspiration;finally,interpret the value The rationality and feasibility of applying the chain theory to crossborder anti-tax avoidance collection management,and proposed to improve cross-border anti-tax avoidance laws and regulations based on the value chain theory;speed up the improvement of China’s anti-tax avoidance legal system;improve the tax-related dispute resolution mechanism,and strengthen the tax certainty of cross-border enterprises Three countermeasures for cross-border corporate tax avoidance. |
