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党的十一届三中全会实行对外开放的政策以来,为了适应吸收外资,引进技术,对外发展经济技术合作的需要,我国政府一方面积极建立涉外税收制度,另一方面,积极开展了对外谈判和签订对所得避免双重征税和防止偷漏税的协定工作。从1981年初开始到现在,我国已先后同日本、美国、英国、法国、联邦德国、比利时、民主德国、新加坡、马来西亚、加拿大、芬兰、丹麦、挪威、瑞典、新西兰、捷克斯洛伐克、波兰、泰国、意大利、荷兰等二十多个国家分别签订了避免双重征税的协定。目前还有一些国家正在同我国谈判有关税收协定。在这种情况下,如何妥善地处理国际税收协定同涉外税法的相互关系,就成为值得研究和需要引起足够重视的问题。在实际工作中,
Since the Third Plenary Session of the 11th CPC Central Committee has implemented the policy of opening to the outside world, in order to meet the need of absorbing foreign investment, introducing technology and developing economic and technological cooperation with other countries, the Chinese government has actively established a tax system concerning foreign affairs. On the other hand, it has actively conducted negotiations with foreign countries And signing an agreement on the avoidance of double taxation on income and the prevention of tax evasion. From the beginning of 1981 to the present, our country has held close cooperation with Japan, the United States, Britain, France, the Federal Republic of Germany, Belgium, Democrat Germany, Singapore, Malaysia, Canada, Finland, Denmark, Norway, Sweden, New Zealand, Czechoslovakia, Poland, Thailand, Italy, the Netherlands and more than 20 countries have signed an agreement to avoid double taxation. There are still some countries that are negotiating tax treaties with my country. Under such circumstances, how to properly handle the interrelationship between international tax treaties and foreign tax laws has become a problem that deserves to be studied and needs to be given sufficient attention. In practical work,