本文归纳出我国涉外税收争议的发生主要集中在四个方面:所得类型的争议、常设机构认定的争议、涉外技术服务征税的争议、避税行为性质的争议。通过对这些争议焦点的剖析,可以为我国涉外税收的立法与实践提供有益的参考。 This article concludes that the tax disputes in our country mainly focus on four aspects: the types of disputes, the disputes of permanent establishments, the disputes of taxation of foreign technical services and the nature of tax avoidance. Through the analysis of the focus of these disputes, we can provide a useful reference for the legislation and practice of China’s foreign tax revenue.