近几年来,随着中国经济的不断发展,尤其中国加入WTO后与世界经济的接轨日益加深,许多企业综合采用多种避税手段,以便最大限度地减少税收支出,“资本弱化”即为企业的避税手段之一。为了规范企业关联方借款利息支出的税前扣除,防止企业利用资本弱化避税,削弱国家的税基,我国制定了一系列的法律、规范性文。本文结合国家的各类法律、法规,对关联企业间借款利息的所得税税务处理进行探讨。 In recent years, with the continuous development of China’s economy, especially after China’s accession to the WTO, its integration with the world economy has been deepening. Many enterprises have adopted a variety of tax avoidance measures in a bid to minimize tax expenditures. The “capital weakening” is Tax avoidance means one of the enterprises. In order to standardize the pre-tax deduction of the loan interest expenses of the affiliated enterprises and prevent the enterprises from using the capital to weaken the tax avoidance and weaken the country’s tax base, China has formulated a series of legal and regulatory documents. In this paper, the various types of laws and regulations of the country, to explore the income tax treatment of interest on borrowings among affiliated enterprises.