A Study On Tax Avoidance And Anti-tax Avoidance Of VIE Structure Corporate

The Alibaba Group and the Tencent Group took turns to the peak of the Value of Asia listed company in 2016 year.In fact,the TMT industry developed well,and the McKinsey global institute reports said that 7-22%of the increment of GDP would be from internet industry.The Alibaba Group,the Tencent Group,the Sina Group,the JD Group,the Netease Group in the TMT industry,and the New Oriental group,the CDEL group,the TAL group,the Xueda Education group,they are all Overseas-listed company with the VIE Structure.As a tax worker,it' s important to analysis the tax risk of VIE Structure company,and find the anti-tax avoidance scheme.The VIE Structure is a reverse utilization of FIN46 clauses,by China enterprises in the pursuit of overseas listing to circumvent the layer of approval,regulatory breakthrough industry access restrictions.Generally speaking,the more business categories under the structure,the more the intermediary companies,the more complex the entire VIE Structure.It will be this paper' s contribution to anti-tax avoidance,if I can analysis the tax avoidance strategy of VIE Structure enterprise,find the anti-tax avoidance scheme to the VIE Structure which is already very large.I hope my study will be Benefit to the tax administration of the VIE Structure enterprise,under the big background of BEPS Plan,which was pushed by G20 Group.This study contents five chapters.Chapter one is the introduction.Chapter two is the analysis of the tax avoidance link.The flow status of the funds in the VIE Structure is described by literature search and case study.The author recognizes that there are three potential links of tax avoidance of the VIE Structure enterprises.Chapter three is an analysis of the avoidance strategy of each link we found in Chapter two.Chapter four is an analysis of the anti-avoidance scheme of each link.Chapter five is a framework of anti-tax avoidance about VIE structure enterprises.With a strong inquiry into the VIE Structure enterprise and a sense of responsibility for protecting national tax benefits I started this study.Comparing to the complex VIE Structure,its complex operational planning,my study has improvement space,but I' m really sure it can provides a framework for the follow-up of the anti-avoidance work of the VIE Structure enterprises.The innovation of this study I think may have the following two points:first,my object,the VIE Structure itself is a breakthrough financing and regulatory restriction innovation mode,my study on its tax avoidance and anti-tax avoidance has certain new meaning;second,from the VIE Structure enterprises funds flow into the three high tax avoidance links,a whole process observation was made.I know the information asymmetry may affect the depth of the study.Because of the lack of documentation and the complexity of VIE Structure itself.But I' m sure I can do it better and better,as the practice deepens.