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《外商投资企业和外国企业所得税法》和《中华人民共和国企业所得税暂行条例》两个法律的统一(简称“两法统一”,又称“两税合并”),一直以来是理论界公认的税制改革方向,但因为实际情况不成熟,而只是停留在理论探讨阶段。最近一段时间两法统一提上了日程。本文通过分析两法统一的基本框架和过渡期基本措施,初步探讨两法统一对外资企业和内资企业的税收影响。
The unification of the two laws (the “unification of two laws” or “two-currency merger”) between the Income Tax Law of Foreign-invested Enterprises and Foreign Enterprises and the Provisional Regulations of Enterprise Income Tax of the People’s Republic of China has long been recognized as a tax system in theorists The direction of reform, but because the actual situation is immature, but only stay in the theoretical discussion stage. Recently, two laws have been put on the agenda. By analyzing the basic framework of the two laws and the basic measures during the transitional period, this article initially explores the tax implications of the unification of two laws on foreign-funded enterprises and domestic-funded enterprises.