The Overseas Investment Tax Risks And Strategies Of Enterprises Under The Policy Of OBAOR

With the continuous advance of the "One Belt And One Road" strategy,China has gradually shifted to the great power exporting countries,and more and more Chinese enterprises have gone abroad to make overseas investments in countries along the belt and road.For these "going out" companies,while there are vast commercial opportunities in overseas markets,there are also huge risks,among which the tax risks are an important part.Under the impetus of the G20 summit to transfer profits tax base erosion and 15(BEPS)action plan,new international tax rules have been established preliminarily,between capital exporter and importer on tax competition and the contradiction of the new rules apply to more and more apparent.China's "going out" enterprises overseas investment of time is short,less experience,tax risk consciousness,lack of risk management,there are few enterprises to establish a comprehensive tax risk management system,in the period of new international tax rules will encounter a lot of unknown tax risk.The tax risk embodies in two aspects:on the one hand,because there is no make good use of the host country of the tax law and tax agreements in China,lead to enterprise unconscious more tax,adding to the enterprise tax burden;Also lead to enterprise,on the other hand,the unconscious less tax,breaking the foreign tax law,to the reputation of the enterprise and government relations cause adverse effect,is not conducive to enterprise overseas investment management,affect the enterprise survival and development in the host country.Based on this,this article based on the enterprise overseas investment process,analysis may encounter the tax risk,and puts forward specific risk for strategy,aims to help control the risk of "going out"enterprises,increase profits.This paper is divided into five parts.The structure is as follows:Chapter one,introduction.Mainly introduces the research background and research significance of the article,and from all the way "area" the enterprise overseas investment tax risk classification,causes and coping strategies of the three angles of the current research achievements were summarized,the article also introduced the overall research content and structure,the use of the main research methods and innovation points and shortcomings.The second chapter,"One Belt And One Road",the basic analysis of enterprise overseas investment and tax risk.This chapter mainly analyzes the two problems of overseas investment and tax risks.The basic analysis of foreign investment in enterprises is carried out from four aspects:investment mode,stage division,investment status and necessity.In terms of tax risks,the tax risks are defined first,then the special characteristics of overseas investment tax risks are put forward,and the necessity of dealing with the tax risks of overseas investment is introduced.Chapter 3,"One Belt And One Road",the analysis of the tax risks of enterprises overseas.This chapter from the start of the overseas investment,operation and exit the stage from three aspects of enterprise tax risk analysis,strive for as far as possible comprehensively covers enterprise may encounter the tax risk points.Specifically,the tax risks of the start-up phase include the risk of tax environment difference,the choice of organizational form and the risk of the holding structure;The tax risks of operation phase include double taxation risk and anti-tax investigation risk;The tax risk of exit phase includes the risk of choosing exit mode and the risk of tax dispute.The fourth chapter,"One Belt And One Road",the analysis of the causes of overseas investment tax risks.This chapter mainly analyzes from both macro and micro perspectives.The causes of macroscopic aspects include political risk,economic risk and historical and cultural difference risk;The microcosmic reasons include the inadequate preparation of enterprises and the imperfect management system of foreign taxation departments.Chapter five,strategies to deal with the tax risks of foreign investment under One Belt And One Road.This chapter puts forward strategies to deal with the tax risks from the enterprise level and the national level.At the enterprise level,according to all kinds of risks,the third chapter mentioned specifically from the company organization form and the choice of holding structure,financing way and let the pricing rules and tax dispute resolution strategy is put forward.Make "go out" enterprises to arrange business activities as reasonably as possible,avoid tax risks,thus reduce tax burden and enhance international competitiveness.At the national level,because of the "going out" enterprises want to in the heart of the overseas business process to minimize the tax risk,achieve higher profits,improve the position in international competition,not only need to be self building,at the same time also need strong support to national tax authorities.Therefore,this chapter puts forward the corresponding policy Suggestions from improving the foreign income tax policy,enhancing the tax agreement and improving the foreign tax service and management.