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税基侵蚀和利润转移(BEPS)的根本原因,不仅在于避税地的广泛存在,而且在于发达国家主导的不公平的价值创造理论过度提高了无形资产的价值,还在于复杂的无形资产转让定价方法。发达国家是资本和技术输出国,在过去多年的国际税收竞争中取得了不公平的税收利益,应该承担更多的国际责任。解决BEPS应引导传统避税地转型,公平评价生产商品和提供服务的每一环节所创造的价值,逐步推进按公式分配法划分国家税收权益。
The root cause of the tax base erosion and profit transfer (BEPS) lies not only in the widespread existence of tax havens, but also in that the unfair value creation theory led by developed countries excessively increases the value of intangible assets and also lies in the complicated methods of transfer pricing of intangible assets . The developed countries, as the exporters of capital and technology, have obtained unfair taxation benefits in the international tax competition over the past years and should assume more international responsibilities. To solve the problem that BEPS should guide the transformation of traditional tax havens, evaluate the value created by every aspect of producing goods and providing services equitably, and gradually push forward the allocation of state tax rights according to the formula of distribution.