运用避税港避税是跨国纳税人从事大量避税活动的重要途径,许多国家的税收利益由此受到了极大的损害,而西方发达国家受损则尤为严重。因此,西方主要发达国家如美国、德国、英国、日本、法国和加拿大已先后制定了反运用避税港立法,包括澳大利亚和新西兰也已形成了反运用避税港立法提案,比利时和荷兰则在有关的立法中制定了反运用避税港条款。由于各国的反运用避税港措施主要是针对受控外国公司的,因而它们常常又被称作受控外国公司立法(或条款)。各国的反运用避税港立法的目的均在于对付本国居民通过在建立于避税港的外国居民公司(即受控外国公司)拥有一定量的股权来避免本国税收的行为。这一般是通过将受控外国 Tax avoidance is an important way for multinational taxpayers to engage in a large number of tax avoidance activities. Tax benefits in many countries have thus been greatly impaired, while developed countries in the West have been particularly damaged. Therefore, the major western developed countries such as the United States, Germany, the United Kingdom, Japan, France and Canada have successively enacted legislation on anti-trafficking and tax havens, including the proposal of legislation on anti-trafficking and tax havens in Australia and New Zealand. In Belgium and the Netherlands, Legislation enacted a clause on the use of tax havens. Since countervailing and tax havens in various countries are directed primarily at controlled foreign companies, they are often referred to as legislation (or provisions) by controlled foreign companies. The purpose of each country’s anti-exercise of tax havens is to counteract the domestic taxation of its residents by holding a certain amount of equity interest in a foreign resident company (ie a controlled foreign company) established at a tax havenship. This is generally done through a controlled foreign country