当前我国税收饶让制度的发展在税收协定的缔约数量、缔约对象、缔约区域、缔约类型、缔约内容等方面均呈现出自身的发展特点,同时也面临国际社会对税收饶让制度立场发生重要转型以及我国现行税收饶让制度普遍存在缺陷的问题。今后,我国税收饶让制度将面临必要的结构性调整,而对现行税收饶让条款进行逐步完善亦是合理的选择。 At present, the development of China’s tax sparing system shows its own development characteristics in terms of the number of contracting parties, contracting parties, contracting parties, types of contracting parties, contents of contracting and so on. At the same time, it also faces an important transformation of the international community in regard to the system of tax sparing As well as the current defects in China’s tax sparing system. In the future, the tax levying system in our country will face the necessary structural adjustment, and it is also a reasonable choice to gradually improve the current tax sparing clause.