跨国投资所得往往由于各国税收管辖权的交错和重叠,被来源国和居民国课以双重甚至多重所得税。为消除这种国际重复课税,国际税收协定和税收抵免制应运而生,其中抵免制为资本输出国的国内举措发达的资本主义国家如日本和美国在长期的国际经济交往中总结出一套较为系统、完善的抵免制,值得我国涉外税收工作者的研习。 Transnational investment income often due to the staggering and overlapping tax jurisdictions in different countries, countries of origin and residents of the country by double or even multiple income tax. In order to eliminate such international double taxation, international tax treaties and tax credit systems came into being, among which capitalist countries such as Japan and the United States, which developed domestic measures of credit-issuing as capital-exporting countries, summed up in long-term international economic exchanges A more systematic and complete credit system, it is worth our foreign tax workers study.