一、涉外税收法律冲突的产生 (一)、涉外税收法律冲突的含义。涉外税收法律冲突,是指国际间某种涉外税收法律事实,即跨国纳税人的某种涉外经济活动,涉及到两个或两个以上不同国家的税收法律,而相关国家的税法对由该法律事实产生的涉外税收法律关系的规定不一致,但又都要按照本国的税法规范来进行调整的现象。例如,一家在美国登记注册的公司,在中国设立一个常设机构进行经营活动,对于这一法律事实, First, the tax conflicts arising from foreign laws (A), the meaning of foreign tax law conflict. The legal conflicts in foreign taxation refer to some international legal fact concerning foreign taxation, that is, some kind of foreign economic activity of transnational taxpayers involves the taxation laws of two or more different countries, and the relevant tax laws of the country In fact, the provisions of the legal relations concerning taxation involving foreign interests are inconsistent, but they must all be adjusted in accordance with the tax laws and regulations of their own country. For example, a company registered in the United States to establish a permanent establishment in China to conduct business activities, for this legal fact,