我国税务机关开展间接转让征税以来,极少数税务专家持不同观点。如有的认为国税函[2009]698 号文件的法律依据不足,违背了上位法的相关规定 ;有的认为税务机关滥用一般反避税规则,侵犯了境外投资者的合法税收利益。如何正确看待上述观点,并采取相应的措施予以应对,是税务机关急需解决的重大问题之一…… Since the tax authorities in our country conducted indirect tax transfers, a very small number of tax experts hold different views. Some people think that the legal basis of Guoshuihan [2009] No. 698 file is not enough, which violates the relevant provisions of the above-mentioned laws. Some people think that the tax authorities abuse the general anti-avoidance rules and violate the legitimate tax benefits of overseas investors. How to correctly view the above point of view and take corresponding measures to deal with them is one of the major issues which the tax authorities urgently need to solve ......