China has become the largest foreign direct investment country in the world.
One of the inflow countries. However, the profits of state-owned enterprises, collective enterprises and private enterprises have increased.
At the same time, the profits of foreign investors and investment enterprises from Hong Kong, Macao and Taiwan have appeared instead.
Decline, and the loss is gradually expanding, has reached 60%~65%. This is strange.
This strange phenomenon has attracted the attention of all parties. On the one hand, 60% of foreign companies lose money, one
The losses of some multinational companies are increasing every year; On the other hand, I came to China.
The amount of foreign investment in land has been steadily rising, and the investment and occupation are constantly increasing.
The market share is expanding year by year. According to the data released by the National Bureau of Statistics, China
60% loss of foreign-funded enterprises is abnormal, which is caused by tax avoidance.
For the loss. It is estimated that the annual tax avoidance by multinational corporations will generate tax revenue for China.
Losses of more than 30 billion, due to personal income tax, business tax, etc.
Tax is not included, so the actual tax loss far exceeds this.
Numbers. With the deepening and expansion of economic globalization, we should seize multinational companies.
The main method of tax avoidance is to explore and improve China's international anti-tax avoidance ability.
It has important theoretical and practical significance.
Second, the main methods of tax avoidance by multinational corporations
(1) Transfer tax entity
The transfer of tax subject is to get rid of or avoid the tax jurisdiction of high tax countries.
Reduce the tax burden. In countries where legal standards apply, multinational companies only need to
Revocation of registration in high-tax countries and registration in other countries, namely
Yes In countries where household registration standards apply, multinational companies can cancel this structure.
Factors that control and manage institutions, such as using false relocation management institutions.
Out, change the company system and other practices, avoid the existence of residence, get rid of high taxes.
China's tax jurisdiction. The transfer of taxpayers can also rely on the establishment of intermediary institutions.
Institutions, fictional tax havens, abuse of tax agreements and other disguised tax avoidance subjects.
Transfer realization. Abuse of tax treaties is one of the common methods. for
Avoid international double taxation, coordinate international tax distribution and promote international tax revenue.
Countries usually conclude tax agreements on cooperation in tax collection and management.
There are about 4000 bilateral and multilateral tax treaties around the world. tax convention
There are usually mutually favorable terms between contracting States, such as dividends and profits.
Interest, royalties and other withholding taxes, many of which are mutually reduced or even exempted.
Tax provisions. Due to the differences in the interpretation of tax systems and tax treaties in different countries
Differences or omissions, not residents of some contracting parties, that is, they do not meet the conditions of the agreement.
Preferential multinational taxpayers, through the establishment of various intermediary companies, such as direct channels
Company, pedal stone pipeline company, foreign low-equity holding company, etc. , try
Enjoy the preferential treatment of the agreement, so as to reduce the tax burden.
(2) Transfer pricing
Transfer pricing, also known as transfer pricing, refers to the internal and external of the company group.
Other relevant units, specially formulated for mutual transactions.
Internal settlement price. Not affected by the supply and demand relationship in the international market.
Only obey the global strategic objectives of multinational companies and maximize their global interests.
Target. According to statistics, at present, nearly 60% of international trade is conducted by multinational companies.
Internally, in the internal transactions of affiliated enterprises, transfer pricing is often
The most important means for multinational corporations to avoid tax. Common manifestations of transfer pricing
There are commodity purchase and sale, credit financing, provision of labor services, purchase and lease of fixed assets,
The use and transfer of intangible assets. Multinational companies raise or lower commodity prices.
Materials, loan interest rate, service fee standard, depreciation of fixed assets, intangible assets
The costs and profits of the relevant enterprises in the use and transfer of royalties.
Exert influence to transfer profits from high-tax countries to low-tax countries to reduce transnational.
The purpose of the company's overall tax burden
(3) Using international tax havens
International tax havens mean that some income taxes and general property taxes are not levied or
The tax rate is very low, or special tax incentives are provided to non-residents, thus forming
Countries and regions that have become centers of international tax avoidance activities. Currently, there are
There are many international tax havens, the most famous of which are Virgin Islands and Cayman Group.
Island, Bermuda and other regions. The world economy is increasingly liberalized and integrated, and the international
With its convenient financial services and relaxed tax environment, tax havens have become
Many companies around the world are registered places and tax havens. Multinational companies use international
The means of tax avoidance in tax havens is mainly through the establishment of independent tax haven laws.
The identity of the base company, as an intermediary for resale transactions, or through
The base company carries out transfer pricing, and the profits are kept for use by the base company.
Preferential policies to reduce tax burden in tax havens.
Third, the current situation of China's international anti-tax avoidance work
China's anti-tax avoidance work against multinational companies started late, but it has made progress.
Still relatively fast. Since 1992, China has gradually started from the legal policy side.
Face to do a lot of work, People's Republic of China (PRC) State Taxation Administration of The People's Republic of China released "about affiliated enterprises.
Measures for the implementation of inter-industry tax management and several specific problems
Attention. Especially in 2004, State Taxation Administration of The People's Republic of China issued the "affiliated enterprises"
Detailed Rules for the Implementation of Advance Pricing for Business Transactions (hereinafter referred to as Advance Pricing) Confirmation of Associated Enterprises
Fixed, related party transaction price adjustment and so on have made many detailed provisions, in the prevention.
Multinational companies maliciously avoid taxes, coordinate with multinational companies, and reduce tax costs.
And other aspects. The formulation and implementation of these regulations is a violation.
Tax avoidance provides a strong legal guarantee, which initially constitutes China's international.
Framework system of anti-tax avoidance system. People's Republic of China (PRC) and State Taxation Administration of The People's Republic of China also established State Taxation Administration of The People's Republic of China.
International anti-tax avoidance agencies have promoted the development of international anti-tax avoidance work. But for the purpose,
Looking at the actual situation before, the overall effect of China's international anti-tax avoidance is still neglected.
Yes, the main problem is: 1. China's international anti-tax avoidance situation is influenced by various places.
Pay insufficient attention to the severity and lack understanding of its characteristics and performance rules; no
Few tax authorities below the provincial level do not have a special international anti-tax avoidance machine.
The structure and personnel are weak, and there is a lack of high-quality anti-tax avoidance talents. 2. I
China's economic system is in a transitional period, and the development of various markets is still incomplete.
Kindness and information asymmetry exist in a large number, and information enjoyment is flawed.
Product prices and other related information are difficult to grasp. 3. China's tax collection and management system and
The market supervision system is not perfect, lacking advanced modern collection and management means, lacking
Lack of a set of scientific, rigorous and standardized operating procedures and methods. Be taxed
Cost and other social factors, tax authorities and relevant overseas tax authorities
Bureau of information exchange and cooperation has not been fully carried out, international institutions.
Lack of communication and cooperation brings difficulties to the anti-tax avoidance work.
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