引言新的全球经济环境促使世界各国重新调整其税制结构和税收政策之时，税收饶让的做法越来越引起人们的注意。税收饶让尽管使一些国家和公司得到了实惠，保证了投资公司非居住国（即被投资国，本文主要是指发展中国家）税收优惠的实现，维护了国际投资者的利益，同时也鼓励了 Introduction When the new global economic environment prompts countries in the world to readjust their tax structure and taxation policies, the issue of tax sparing is attracting more and more attention. Tax Ranging Despite the fact that some countries and companies have benefited from it, it has guaranteed the realization of tax incentives for investment companies in non-resident countries (that is, invested countries and this article refers mainly to developing countries), and has protected the interests of international investors as well as encouraging It’s