随着经济全球化趋势的深入发展,我国经济与世界经济日益融合,税收国际化问题日益凸显,尤其是非居民企业税收征管漏洞大、税款流失严重。为此,国家税务总局在2009年年初密集下发了《非居民企业所得税源泉扣缴管理暂行办法》(国税发[2009]3号)、《非居民承包工程作 With the further development of the economic globalization, the economy of our country is increasingly integrated with the world economy and the internationalization of taxation has become increasingly prominent. In particular, non-resident enterprises have a lot of loopholes in tax collection and administration and serious loss of tax revenue. To this end, the State Administration of Taxation issued in early 2009, “Non-resident Enterprise Income Tax Withholding Management Interim Measures” (Guo Shui Fa [2009] No. 3), "non-resident contracted projects