近年来，世界各国诸多反避税法律中，受控国外公司的税法发展最快。虽然世界各国对其居民纳税人控制的国外子公司行使其税收管辖权原则都很相似，但也存在着一些明显的差别。所谓受控国外公司法律就是为防止国内纳税人设在低税国的海外公司的资金积累，各国对其国内纳税人有参 In recent years, many anti-avoidance laws of all countries in the world have developed the most rapidly in the tax law of controlled foreign companies. Although the principle of tax jurisdiction exercised by foreign subsidiaries controlled by their resident taxpayers in various countries in the world is similar, there are some obvious differences. The so-called controlled foreign company law is to prevent the domestic taxpayers located in low-tax countries, the accumulation of funds of foreign companies, each country on its domestic taxpayers have ginseng