The Study Of Special Rules For Foreign-related Tax Adjustments

To prevent tax avoidance has always been a multinational field of taxation of each sovereign state an important issue, China is no exception. Carry out the work of anti-avoidance as not a long time, although some success has been achieved, but in theory and in practice there are still many deficiencies. Based on the work of anti-avoidance situation and on the basis of the existing problems on the "Implementation Measures for Special Tax Adjustments" to explore.This thesis includes five parts, through the United States, Japan, Britain, Australia and other developed countries a comparative analysis of the legal system, combined with our legislative status and problems in practice, put forward a number of its recommendations, in a bid to China foreign Special tax to make some contribution.The first part of the "special tax rules for foreign Overview ", the first concepts of tax avoidance gives a brief introduction, then the concept of special tax rules were introduced, the clarity of these concepts for the following specific rules on the interpretation of research together with the Consul-General role. Finally, the important concepts of the topic of special tax rules for foreign-related analysis, a detailed analysis of the "foreign" are specifically targeted, this is a major innovation of this article.The second part of the "APA rules", a brief background of the APA system are introduced, then a detailed analysis of the system of advance pricing problems, and puts forward a sound system of Advance Pricing Strategies.The third part of the "controlled foreign companies rules," the first rules of the controlled foreign companies to define, and then describes some of the developed countries, the main provisions of the controlled foreign company rules, controlled foreign companies according to rules of the shortcomings improve the formation of the controlled foreign companies rules proposals.The fourth part of the "thin capitalization rules," the first clear concept of thin capitalization, introduced thin capitalization rules of major content and status, followed by analysis of the major countries of the measures against thin capitalization and, ultimately, improve our capital dilution summarized tax system response. The fifth part of the "other special tax adjustment measures" were introduced briefly, transfer pricing rules, cost allocation and management rules commonly agreement tax provision. This section is mainly to the foreign special tax adjustment rules, and tries to make, adding that the whole article keep narrated complete plump.