Research On Perfecting The Tax System Of Controlled Foreign Companies In China

Since entering the 21 st century,the economic links between countries in the world have become closer.The shared information and developed logistics have promoted the economic exchanges among various countries,and the process of economic globalization has accelerated rapidly.Under the background of this era,the rapid development of multinational corporations brings more tax benefits to governments on the one hand,but on the other hand,transnational tax avoidance activities continue to emerge in an endless stream.It is one of the main means for multinational corporations to avoid tax through the establishment of controlled foreign companies.Using this form of tax avoidance has also become a tax avoidance by tax authorities in various countries.In order to safeguard the neutral principle of taxation and create a fair competitive environment,China introduced a controlled foreign company tax system in 2008.It has been continuously improving after continuous practice for 10 years.However,there are still some areas that need constant exploration and continuous improvement.In this era of rapidly changing international economy and the constantly changing international taxation system,taking into account China's national conditions,major development strategies such as the “One Belt and One Road” are now at a critical juncture.At this time,it is urgent to improve the tax system of controlled foreign companies that are accurately positioned,improve national conditions,protect China's tax base from erosion,and effectively improve the competitiveness of China's “going out” enterprises.This article clarifies our country's current tax system for controlled foreign companies by referring to domestic and international literature on the policy of introducing a tax system for controlled foreign companies,and from the perspective of anti-avoidance taxation,there arestill many problems in our current tax system,such as "control" standards are not clear,"reasonable commercial purpose" is not sufficient,the substantive law determines the taxable income is unfair,the tax evasion is not reasonable,the exemption is not comprehensive and other issues.By referring to foreign developed countries,such as the United States,Germany,the United Kingdom,Japan,etc.,to deal with the above issues,this paper considers China's current tax environment and the level of management,and proposes relevant solutions.