随着2008年《企业所得税法》及实施条例等一系列法律法规的颁布和实施,我国初步搭建了以固定比率法为主,以正常交易原则为辅的资本弱化税制框架。从近年来的运行实践情况看,取得了一定的效果,但关于债权性资金的确定、比例的确定等方面的规定仍相对粗简,相关条款仍需进一步细化。 With the promulgation and implementation of a series of laws and regulations such as the “Enterprise Income Tax Law” and its implementing regulations in 2008, China has preliminarily set up a capital weakening tax framework based on the fixed-ratio approach and supplemented by the normal trading principle. Judging from the operational practice in recent years, some effects have been achieved, but the provisions on the determination of the determination of the claims and the determination of the proportion are still relatively crude and the related clauses still need to be further elaborated.