Tax Policy Research On Alleviating Hybrid Mismatch Arrangement In China

With the continuous development of globalization and the acceleration of international economic exchanges,contradictions caused by the mismatch of domestic and foreign tax rules have become increasingly prominent.Multinational corporations use the mismatch to make tax avoidance arrangement,which is known as hybrid mismatch arrangement.It not only causes tax base erosion and profit shifting,but also aggravates unfair market competition and affects the efficiency of capital operation.In order to reduce its harm in China and make the tax policy more effective,tax policies of alleviating hybrid mismatch arrangement in China are studied,and some suggestions are put forward.Firstly,the basic concept of hybrid mismatch arrangement is defined,the connotation and theoretical basis of hybrid mismatch arrangement are summarized,five types are divided.Then,the perspective in China is focused,coping measures from comprehensive anti-tax avoidance regulations,hybrid financial instrument regulations,multilateral tax agreements,international tax management are concluded,the impact of various types of hybrid mismatch arrangements is analyzed,the existing problems of anti-mismatch policies are analyzed.Then,the experience of alleviating hybrid mismatch arrangement is analyzed,the anti-hybrid mismatch policy of OECD,EU and US are summarized,and the tax avoidance principles,the successful implementation factors,tax investigation results are analyzed,and the influence of the case from the perspective of practice is analyzed,combined with the case of MC Group’s branch mismatch tax avoidance.Its effective practice is learned,and problems in its implementation are reflected.Finally,based on the national conditions in China,the thesis draws the suggestions of alleviating hybrid mismatch arrangement.China should strengthen the judgment of hybrid mismatch arrangement starting from normative formal and material requirements,revise tax policy from the perspective of introducing systematic policies and improving policies with mismatch risk,and improve tax agreements from perfecting the consultation mechanism of dual resident entities and increasing the anti-mismatch clause.Strengthening tax information disclosure,information exchange,international tax team construction to strengthen antimismatch international tax management.