据统计，我国目前引进外资额实际已达到上千亿美元（截止1997年上半年，合同额已达到三千亿美元），随着我国经济的快速发展，外商投资企业和外国企业乃至国内企业避税的问题越来越突出，防范避税已成为我国税收征管中需重点研究的课题之一。据美国国内收入局的报告中关于美国 According to statistics, the amount of foreign capital actually introduced in our country has actually reached hundreds of billions of U.S. dollars (the contract value has reached 300 billion U.S. dollars in the first half of 1997). With the rapid economic development in our country, foreign-invested enterprises, foreign enterprises and even domestic enterprises have avoided tax The issue has become more and more prominent. The prevention of tax avoidance has become one of the topics to be studied in tax collection and administration in our country. According to the report of the U.S. Internal Revenue Agency about the United States