| In recent years,Chinese companies have set off a new wave of overseas listing by VIE structure.By designing multi-level enterprises at home and abroad and building various control relationships through agreements,VIE structure not only avoids domestic restrictions on investment in specific industries and obtains overseas financing needs,but also transfers earnings to overseas smoothly by controlling domestic operating entities,successfully realizing transnational tax avoidance.This tax avoidance mode leads to the serious erosion of our tax base,and a large amount of taxable profits are transferred overseas,resulting in a serious loss of national tax revenue.Therefore,our country has the strong demand against tax avoidance in the VIE structure company.At present,our anti-tax avoidance policy can solve part of the problem of tax base erosion and profit transfer,so it is necessary to improve the relevant anti-tax avoidance policy.This paper will study this problem.From the perspective of anti-tax avoidance,this article takes the tax benefits of our country as the starting point,takes the VIE structure enterprise as the research object and takes the enterprise capital flow as the breakthrough point.The VIE structure enterprise breaks the tax avoidance model into the structure,operation and dismantling stage and analyzes the taxrelated process in each stage.Elaborate each link may appear corporate tax avoidance strategy.Subsequently by analyzing the applicable policy in our country tax authorities’ anti-tax avoidance practice on the basis of relevant cases,and finding out the defects in the current domestic anti-tax avoidance policy theory and practice.Finally,according to the new domestic and international changes of anti-tax avoidance,this paper proposes new countermeasures and suggestions for our country’s tax authorities against the VIE structure corporate tax avoidance model. |
