发展中国家为鼓励外国资本输入,有特别规定的税收优惠待遇(降低税率或在一定时期内免税),但外国投资者能否享受到这种税收优惠待遇,则视居住国(即外国投资者所属国)政府是否采取相应的措施予以合作而定。若居住国政府坚持对国外分公司的直接抵免与对国外子公司的间接抵免,也就是说,国外分公司的所得要在所得发生的年度课税并给予外国税收抵免,而国外子公司的所得通常只在其汇到母公司时才在母公司的居住国课税,届时给予外国税收抵免,即居住国政府不予以合作,不提供相应的税收减免,则外国投资者本身享受不到这种利益,而由居住国获得全部税收优惠的好处。实际上,这部分税款是取自来源国(即 In order to encourage foreign capital input, developing countries have preferential tax treatment (reduction of tax rate or tax exemption within a certain period of time) specially provided for by foreign investors. However, whether foreign investors can enjoy the preferential tax treatment depends on whether the country of residence (ie foreign investor The host country) whether the government take corresponding measures to cooperate. If the government of your country of residence insists on the direct credit to foreign affiliates and the indirect credit to foreign affiliates, that is to say, the income earned by foreign affiliates should be taxed on the annual income tax and foreign tax credits, The income of the company is usually only taxable in the country of residence of the parent company when it is remitted to the parent company, when a foreign tax credit is granted, ie the government of the country of residence does not cooperate and does not provide the corresponding tax relief, the foreign investors themselves enjoy Without such benefits, the benefit of having the full tax benefit received by the country of residence. In fact, this part of the tax is taken from the country of origin (ie