Research On The Income Tax Of Indirect Equity Transfer Of Non-resident Enterprises

With the continuous development of economic globalization,cross-border investment has become more and more popular,and the phenomenon of transferring equity among non-resident enterprises has become more and more common.As the indirect transfer mode of equity is more concealed,it is adopted by more and more non-resident enterprises.It has become a means of tax avoidance for non-resident companies,which has become one of the focuses in the field of international taxation.In order to safeguard the state's tax sovereignty and ensure that the relevant taxes can be smoothly put into storage,the tax authorities are also constantly exploring the taxation management mechanism for the indirect equity transfer of non-resident enterprises.China has successively issued a series of normative documents to regulate the indirectness of non-resident enterprises.The act of equity transfer is taxed.However,from the perspective of China's tax practice,there are still some problems in the current income tax management of non-resident enterprises indirectly,and there is room for improvement.Based on the case analysis,this paper analyzes the related issues of tax management of indirect equity transfer of non-resident enterprises in China,and finds that the non-resident enterprise's indirect equity transfer income tax system has unsound laws and regulations,and the provisions on the issue of shareholding holdings are vague and reasonable commercial purposes.Problems such as imperfect calculation methods for difficulties and indirect equity transfer,problems in tax collection and management,and imperfect international tax coordination mechanisms.To solve these problems,some suggestions are proposed.Such as the establishment of a sound tax law system,clear generation of shareholding problems,accurate judgment Commercial purposes,improve the taxation supervision system for nonresident enterprises' equity transfer,strengthen the construction of international tax coordination system,and other proposals to strengthen the taxation management of indirect equity transfer of non-resident enterprises in China.