Research On The Tax System Of The Controlled Foreign Compaties In China

In the economic globalization and our country to encourage "going out",China's foreign investment continued to rise,only 2015,the realization of foreign investment is 735 billion80 million yuan RMB,the rapid growth of foreign investment at the same time,the territory of the parent company through the establishment of controlled foreign companies in low tax jurisdictions,profits transferred to foreign subsidiaries in tax avoidance situation continue to appear.In order to combat the erosion of the tax base,China introduced the concept of controlled foreign enterprise in the new enterprise income tax law in 2008,and formulated the rules of controlled foreign enterprise.But there are some defects,such as the control standard is not clear,the main tax that there are omissions,lack of reasonable business purpose defined,these problems need to be solved through the improvement of controlled foreign rule in china.In this paper,through two typical cases of the current corporate tax controlled foreign related legislation in China to sort out,through the analysis of case handling disputes in the process of finding defects in Chinese controlled foreign corporation tax,based on the latest BEPS action plan on the combination of foreign advanced experience put forward the reconstruction of controlled foreign companies in China's tax system recommendations.