Study On The Income Iax System Of Non-resident Enterprises Equity Transfer

With the increasing development of economic globalization,equity transfer characterized by cross-border capital flows have become more frequent,bringing about more diversified tax-related problems.Especially in 2008 the two tax merger resulted in multinational companies in China tax incentives has shrunk dramatically,foreign investors have through equity transfer of assets will be transferred,in order to seek the new tax shelter.In recent years,the non-residential enterprise equity transfer tax management has become one of the priorities of international tax management due to its strong hidden characteristics.Based on careful studies of past research on nonresidential enterprise equity transfer income tax system and combined with the current situation,this article summarizes the existing issues and problems of the nonresidential enterprise equity transfer income tax system and creatively combines some typical non-residential enterprise equity transfer transaction tax avoidance cases exposed in recent years,thus making the problem more clear and putting forth corresponding advice.This paper is divided into five parts.The first one is the introduction,which presents some research background and purpose,some research status quo at home and abroad.It mainly summarizes the papers about the non-residential corporate income tax system equity transfer four aspects: description,analysis,management problems,and improvement.The second part summarizes and analyzes the policies and regulations of non-residential enterprises transfer in our country before the emergence of two taxes,and it provides an overview of the content of international tax treaties.By considering the actual situation that current non-residential enterprise equity transfer income plays an important role,the third part points out the importance of non-residential corporate equity transfer income tax and summarizes the problems and issues existing in the current tax system.The fourth part takes some typical nonresidential enterprise equity transfer transaction tax avoidance cases and analyzes the disputing argument on both parties in these cases deeply.The problems are analyzed and we get some enlightment about intact supervision,taxes law Propaganda.The last part proposes some good suggestions for the problems and issues brought in the third part.