只要税收存在，避税就必然存在，因为税收从某种意义上说，是对纳税人经济利益的侵犯，纳税人必然千方百计地减少或消除自己的纳税义务。跨国纳税人进行国际投资或经营的唯一目的在于追求比在一国内投资或经营更丰厚的利益，而客观存在的各国税收制度的差异使税收规避成为可能 As long as tax revenue exists, tax avoidance will inevitably exist because tax revenue, in a sense, is a violation of the taxpayer’s economic interests. Taxpayers must try their best to reduce or eliminate their tax liability. The only purpose for multinational taxpayers to invest or operate internationally is to pursue more lucrative interests than investing in or operating in a country. However, the objective existence of tax system differences in various countries makes tax evasion possible