The Study On Tax Law Of Stock Transfers In Non-resident Enterprises

Based on recently issued income tax regulations on equity transfers of non-resident enterprises, this article is devoted to compensate the defections of existing legal regime through analyzing the articles of the regulations and summarizing the practical experience of the governmental agencies.In the first part of this article, the basic situation of non-resident enterprises is introduced to the reader. They can learn some basic knowledges from this part. And this part put basis for the article.In the second part of this article, the defections of existing legal regime are showed before the reader through finding and analyzing the problems of the practical experience.Trying to face the questions from a new angle of view, this article,in the last part of it, attempts to introduce Advance Pricing Arrangement(APA) to deal with them. The upside of this is that we can deal with them in advance to insure state tax revenue and guarantee the tax payer’expectations to achieve a win-win situation.