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根据外商投资企业和外国企业所得税法及其实施细则(以下简称税法、细则)的有关规定,现对外商投资企业来源于中国境外所得的适用税率问题和计算境外已缴纳所得税扣除限额问题,明确如下: 一、根据细则第七十一条,税法规定的减低税率仅适用于外商投资企业在相应地区内从事生产、经营取得的所得。因此,对外商投资企业来源于中国境外的所得,应一律按照税法第五条所规定的税率计算征收企业所得税和地方所得税。
According to the relevant provisions of the Income Tax Law of Foreign-Funded Enterprises and Foreign Enterprises and their Implementing Rules (hereinafter referred to as “Tax Laws and Regulations”), the applicable tax rate of foreign-invested enterprises derived from outside China and the deduction of income tax deductions overseas have been clarified as follows : 1. According to Article 71 of the Articles, the tax reduction rate stipulated in the tax law shall only apply to the income derived by foreign-invested enterprises from engaging in the production and operation in the corresponding areas. Therefore, for enterprises with foreign investment that derive their income from outside of China, enterprise income tax and local income tax should be levied at the rates stipulated in Article 5 of the Tax Law.