Tax Risk And Countermeasures Faced By High And New Tech Enterprise S' Payment Of Royalty

Our country is in the development trend of economic globalization.While constantly absorbing foreign high technology,we are also constantly exploring the path of revitalization of external development.The “One Belt and One Road” initiative proposed by Chairman Xi Jinping focuses on the “going global” and “bringing in” Chinese companies and provides cross-border enterprises with fertile ground for development.At the same time,in practice,multinational companies in various countries and regions have tried to avoid their tax liabilities and have caused tax base erosion in other countries by taking use of the differences in the tax system between countries and the loopholes in international taxation laws.As a result,international organizations and countries have strongly promoted cooperation among countries and revised new international tax rules to suit the development of the new economic situation.With the revision of international tax treaties and improvement of tax laws as well as strict supervision of tax authorities in a great number of countries,Chinese companies will face potential tax risks in the process of cross-border payment of royalties.Therefore,it is of great meaning to explore the way how Chinese companies can reduce the tax risk of enterprises and improve the ability of enterprises to introduce technology and technological innovation.This paper tries to analyze the main tax treaty models among international organizations and the terms of royalties in the tax treaties among countries,as well as the tax agreements and domestic laws and regulations that have already been implemented in China,by literature reading and comparative analysis method.Then we try to explore the potential risks of Chinese companies' cross-border payment of royalty fees from three aspects: the identification of royalties,the Limitation of Benefits,and the risk of tax inspection to take cross-border payment of royalties.This paper takes the high and new tech enterprise P as the research object,and specifically analyzes that it may face three major risks below in cross-border payment of royalties,including identification risk,customs inspection risk,and high and new tech enterprise qualification review risk by using the case analysis method.At the same time,it shows several suggestions for high-tech enterprises to avoid potential tax risks,including paying attention to improving technical service contracts,strengthening internal corporate tax management,paying active attention to relevant domestic and foreign policy changes,when paying cross-border expenses.Finally,related suggestions and countermeasures are proposed to provide reference suggestions for similar enterprises under similar circumstances,in order to cope with possible tax risks.At the same time,it is also expected that the construction of China's taxation system will gradually mature and our government would provide a fair market environment for the operation and development of multinational enterprises.