The Study Of Conforming Of Controlled Foreign Enterprises

It has been five years since the enforcement of our taxation system of controlledforeign enterprises. However, so far there still exist a lot of problems in the system.Especially in the standards conforming controlled foreign enterprises, there areproblems such as not meeting the needs of practice, lacking operating specificationand insufficiently absorbing the useful legal operation of other countries exceptAmerica, etc. These problems make it difficult to apply the legal system from theroot, which leads to the unsatisfactory implement effect. In the past five years, ourdirect foreign investment has continued with a good growth momentum as both thetotal amount of the investment and the range of host countries have further increased.Nevertheless, the phenomena, for example, most host countries (regions) aretax-heavens, native investors focus on management industries and investmentindustries, have not decreased but increased. That means the number of usingcontrolled foreign enterprises to avoid tax has been growth, which needs the taxationsystem of controlled foreign enterprises to play the role it should be. Thus the writerfind the existing problems and their causes by analyze our current legal system andput forward improvement suggestions, such as amending lagging regulations,improving specifications, and adding other useful standards, on the current problemsin the conforming standards of our controlled foreign enterprises by using forreference of the legislation, judicial practice of main countries in the world, and thesesof some scholars and international organizations.