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半个多世纪以来有关专家学者对境外投资所得最优税制理论进行了深入研讨,提出了资本输入中性、资本输出中性、国家中性、资本所有权中性、国家所有权中性等理论,对各国制定境外投资所得税政策提供了有益的理论基础和指导方向。本文介绍了境外投资税收中性理论的发展及在各国的实践情况,在此基础上分析了我国目前境外投资所得税政策,探讨了在经济一体化进程不断深化的环境下,我国境外投资所得税政策的发展方向。
For more than half a century, relevant experts and scholars have conducted an in-depth study on the optimal taxation theory for overseas investment and put forward the theories of capital input neutrality, capital output neutrality, national neutrality, capital ownership neutrality and state ownership neutrality. All countries have made a useful theoretical basis and guiding direction in formulating the overseas investment income tax policy. This paper introduces the development of tax neutral theory of overseas investment and its practice in various countries. Based on this, it analyzes the present policy of income tax of overseas investment and explores the policy of income tax of overseas investment under the circumstance of deepening economic integration Direction of development.