Research On The Regulation Method Of BEPS Rules For Harmful Tax Competition

Harmful tax competition threatens the good operation of the international taxation field,and it is easy to cause unreasonable flow of global capital,which is unfavorable to the overall development of the people,the government,the state and the international community.It can be argued that harmful tax competition will lead to fluctuations in the international economic and trade pattern,which will adversely affect the wealth income and distribution of global residents.At the same time,harmful tax competition is also an important cause of the deterioration of tax base erosion and profit transfer,so it must be regulated.As a new rule for the centuries-old reform of the international taxation field,the BEPS rule pays close attention to the problem of harmful tax competition.Under this background,this paper specifically discusses the harmful tax competition regulation methods under the BEPS rules,so as to achieve the purpose of improving the harmful tax competition awareness and eliminating harmful tax competition.The main body of this article mainly includes four parts:The first part summarizes the problem of harmful tax competition regulation.Firstly,it clarifies the basic concept of harmful tax competition.Secondly,it elaborates the regulations on harmful tax competition regulation in BEPS rules,and then classifies the harmful tax competition regulation methods under BEPS rules.Finally,it emphasizes the necessity of harmful tax competition regulation under the BEPS rules.The second part compares and analyzes the legal methods of BEPS rules and traditional regulation of harmful tax competition,including the comparative analysis of controlled foreign company rules and transfer pricing rules in the unilateral domestic tax regulations.Through comparative analysis,we can know that some of these regulatory methods are playing a good effect,and we need to continue to implement them in the future and promote them to the whole world.However,some regulatory methods are not compatible with the development of the times,and have been comprehensively revised and updated by the BEPS rules.After that,this paper analyzes the shortcomings of the traditional legal regulation of harmful tax competition.The blank of these legal regulation methods needs to be supplemented and improved by BEPS rules.The third part elaborates the improvement of the traditional regulation of harmful tax competition by BEPS rules,including clearing the criteria for identifying substantive activities,forcing the exchange of information on the preferential tax information of the ruling class,and strengthening bilateral and multilateral cooperation to achieve harmful Efficient regulation of tax competition.Through the multi-pronged approach in these aspects,the purpose of regulating harmful tax competition is achieved.The fourth part discusses the impact of harmful tax competition on China's regulation.In response to the advent and deepening of BEPS rules,China needs to actively promote the implementation of the statutory principle of taxation and continuously implement the specific provisions of the BEPS rules,including the introduction of substantive activity standards.Determine the rules for the exchange of tax information.At the same time,China has raised the awareness of regulating harmful tax competition,participated more in the process of reforming and formulating international tax rules,grasped the initiative,and promoted international cooperation to regulate harmful tax competition.These actions can better cope with international harmful tax competition,ensure the orderly operation of global capital,and promote the sound,sustained and healthy development of our economy.