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证券投资基金是一种间接的证券投资方式,委托——代理关系是证券投资基金运作机制的核心,证券投资基金特殊的运作机理对税收制度提出了挑战。我国税法中有关基金征税的内容较少,甚至有所误解,并且在与基金相关的企业所得税、营业税、征税时机和税负公正等方面均存在严重的税制缺陷。本文从税收公平.效率入手,剖析和探讨了以上4个颇有争议的征税问题,以期对我国现行基金税收政策的研究有所裨益。
Securities investment fund is an indirect way of securities investment. Principal-agent relationship is the core of the operating mechanism of securities investment fund. The special operating mechanism of securities investment fund poses a challenge to the tax system. The Tax Law of our country contains little or even some misunderstanding about the fund taxation, and there are serious tax drawbacks in the enterprise income tax, business tax, tax collection timing and tax burden impartiality related to the fund. Starting with tax fairness and efficiency, this paper analyzes and discusses the four controversial tax issues mentioned above, with a view to the study of the current tax policy in our country.