随着改革开放政策的深入贯彻,外商来我国投资举办海产品合作养殖企业日益增多。这类企业的合同一般都规定:中方提供场地并负责经营管理;外方以实物(多为运输工具)或(和)现汇作为合作投资,不参与经营管理,在合作公司以产品按期偿还外方投资本息的前提下(合同中订有利率),外方不再参与利润分配,也不承担亏损,合作期满,不进行清算,合作公司的全部资产归中方所有。也有个别的公司合同规定,用产品偿还完外方全部投资本息后,投资者再有利润的要按协议比例按照中方优先的原则进行分配。对这类企业如何进行所得税的征收管理,我认为是一个值得研究的问题。根据外国企业所得税法的规定,外国企业同中国企业合作生产、合作经营,合作双方应 With the thorough implementation of the policy of reform and opening up, the number of foreign-funded cooperative aquaculture enterprises that come to invest in China has been on the increase. The contracts of such enterprises generally stipulate that the Chinese side shall provide the venue and shall be responsible for the operation and management. The foreign parties shall take the physical (mostly means of transport) or (and) cash exchange as the cooperative investment and shall not participate in the operation and management and shall repay the foreign party on time Under the premise of investing principal and interest (interest rate set in the contract), the foreign party no longer participates in the profit distribution and does not bear the loss. The expiration of the cooperation expires without liquidation. The entire assets of the cooperative company are owned by the Chinese party. There are also individual company contracts, the use of products to repay all foreign capital after the completion of the principal and interest, the investors further profits according to the proportion of agreement in accordance with the principle of priority distribution. How to administer the collection of income tax on such enterprises is, I think, a problem worth studying. According to the provisions of the Foreign Enterprise Income Tax Law, foreign enterprises cooperate with Chinese enterprises to produce and operate cooperatively and both parties should