Our Non-resident Enterprise Income Tax Source Withholding Management Research

International tax is one country with taxpayer cross-border income tax and trading activities the floorboard of the laws and regulations, a country's international tax law has two aspects of content, both personal and residents of residents from foreign income tax company, and including non-resident comes from domestic income taxes. In 2008, the implementation of the new enterprise income tax law, in introducing a non-resident enterprise concept, but also brings a series of international tax policy changes:foreign enterprise income tax law will merge, ending the enterprises with foreign investment and foreign enterprises in domestic super-national treatment; To obtain a non-resident enterprise in our country the interest income from originally of 20% of the reduced 10 percent levy, and to obtain from non-resident enterprise of residents in our country enterprise stock dividends, bonuses and other equity investment income tax. Accordingly, on our international tax research focus of transferred by a wholly foreign-owned enterprise also non-resident enterprise.Tax authorities in accordance with the new policy has formulated a non-resident enterprise income tax collection and management system and pattern, in a certain extent for non-resident enterprise management to determine the direction, but because the new policy of short time, the specific management measures are not clear that factors such as these institutions and mode cannot meet with the trend of global economic integration development increased international trade cooperation needs. Especially executes source of a non-resident enterprise, withholding tax departments concerning the collection content involves a wide range, including both dividends, bonuses, interest income, income from royalties, and including rental income, the transfer of property income and other income, the management content is very complex. On the one hand, a non-resident enterprise source withholding carrying out management of effectively monitor the stable source, improves a non-resident enterprise tax compliance degrees, make more easy to operate and tax recovered in a certain extent to protect the country's tax sources. On the other hand, a non-resident enterprise source current predicament, withholding management also exist tax information are difficult to grasp, lack of specific policy and institutional guidance, professional talents and lack problems caused by a non-resident enterprise could easily evade taxes, especially scattered sources erosion. According to the problems we need to actively seeking a way to solve the problem, improve non-resident enterprise income tax withholding management quality source.Basing itself on the country's a non-resident enterprise source withholding management present situation, introduces the current non-resident enterprise management, such as through the main methods of establishing source-monitoring stand-books of manual and tracking management, combining daily to carry out special assessment to manage a non-resident enterprise sources. On the analysis of source of withholding management means, content, based on the characteristics of a non-resident enterprise income tax, to the plight of withholding management source a concrete analysis. Combined with the developed countries of the advanced management experience proposes strengthening non-resident enterprise income tax withholding management specific advice source, in order to the tax authorities after a non-resident enterprise income tax withholding management provide source of useful advice. In tax policy, perfecting the policy system at the same time should actively provide resident enterprise publicity non-resident enterprise income tax withholding tax policy, strengthen the source of active withholding enterprise withholding consciousness; In the system aspect, must first strengthen withholding withheld enterprise management system, enhance the initiative; Secondly, we should implement key enterprises, and to realize the monitor and control system of a non-resident enterprise high quality monitoring, The third is to establish international information exchange and cooperation system, the greatest degree to retrieve a non-resident enterprise information. Specific operating aspect, firstly, we must improve tax workers to withhold non-resident enterprise income tax source management to know, Secondly broadening source of information channels for withholding tax search non-resident provide safeguard; Three is to establish a high-quality non-resident enterprise management team, Fourth, actively explore against a tax shelter and methods. Finally, the thesis combines a non-resident enterprise royalty check case of concrete research, further verified the author's opinion and suggestion.