The Study On Controlled Foreign Company Anti Avoidance Of Tax Policy In China

With the accelerated process of economic globalization, the importance of international trade become increasing prominent. As the subject of international trade, the Multi-National Corporations through their own transnational flow of trade in promoting national economic growth, and their tax is a major source of tax revenue of the state. In recent years, the Multi-National Corporations erode our country tax base by means of the special form of Controlled Foreign Company, and this condition has become a thorny problem in all countries tax work. It is imperative that our state should promulgate and improve the Controlled Foreign Company tax anti avoidance policy.This article is on the base of collecting of relevant literatures and summarizing the Law of the PRC on Enterprises Income Tax, The Release of Regulations on the inplementation of the Law of Enterprises Income Tax Law of the PRC,Implementing Measures for Special Tax Adjustment(Trial) and their supplementary documents issued by State Administration of Taxation. Combined with the conditions of the Controlled Foreign Company in China and the methods used by the Controlled Foreign Company,it research the main problems of anti avoidance of tax policy of the Controlled Foreign Company and finds the solutions by means of the case analysis.Through the case analysis of this article,there are three problems In the Controlled Foreign Company anti avoidance of tax policy. The first problem is the general anti avoidance environment need to improve. The second problem is the definition of the Controlled Foreign Company exists defect. The third problem is the new tax avoidance methods of Controlled Foreign Company are hard to be deal with. In the last,this article put forward the optimization suggestion for China Controlled Foreign Comapany anti avoidance of tax policy from the construction of anti avoidance environment and the specific measures.