一、关于“避税”和“偷税”这两个概念的看法几年来,我们习惯于把外资企业通过各种方式将利润转移到境外关联企业以偷逃我国税收的现象称之为“避税”,把税务机关针对这种现象采取的措施称之为“反避税”,这样的提法值得商榷。“避税”一语未见诸于税法,在法律条文上找不到它的定义,但据一般认为,避税是纳税人通过合法手段以达到少缴税或不缴税的一种行为。避税既然不是非法,而是合法的那末,根据什么去反对它呢?笔者认为,关联企业之间为了少缴或不缴纳税收的目的,通过抬高原材料进价、压低产品销价等手段将利润转移出境,实际上是一种偷税行为。因为它符合新近公布的《中华人民共和 First, the views on the concepts of “tax avoidance” and “tax evasion” Over the past few years, we have been accustomed to calling the “tax avoidance” phenomenon of foreign-funded enterprises diversion of profits to overseas affiliates in various ways to evade our tax revenue. The tax authorities take measures against this phenomenon called “anti-avoidance”, such a statement is debatable. The term “tax avoidance” has not been included in the tax law, and its definition can not be found in the legal provisions. However, it is generally believed that tax avoidance is a taxpayer’s lawful act of paying less or not paying taxes. Since tax avoidance is not illegal, but legal, according to what to oppose it? In my opinion, in order to pay less or not to pay taxes for the purpose of affiliates, by raising raw material prices, lower product sales prices and other means of profit Transfer out, in fact, a tax evasion. Because it is in line with the recently announced "People’s Republic