近年来,我国境外所得税收抵免政策不断完善,为有效避免境外所得双重征税、保护企业税收权益发挥了重要作用。随着我国“走出去”企业数量增加、范围扩大,境外业务涉及国家和地区日益广泛,由于各国税制差异,部分国家除征收企业所得税外,还征收超额利润税等其他所得税性质的税款,我国企业在境外缴纳的所得税性质的税款种类不断增加。一、我国企业境外缴纳所得税性质的税款种类及税收抵免存在的问题 In recent years, China’s overseas income tax credit policy has been continuously improved, which has played an important role in effectively avoiding double taxation of overseas income and protecting the tax rights and interests of enterprises. As the number of “Going Global” enterprises in our country has increased and the scope has been expanded, the overseas business involves an increasingly wide range of countries and regions. Due to the differences in taxation regimes in different countries, some countries, in addition to collecting enterprise income tax, also levied taxes on other income taxes such as excess profits tax , The tax types of income tax paid by Chinese enterprises abroad have been constantly increasing. First, China’s enterprises to pay taxes outside the nature of tax types and tax credit problems