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我国在对外签署的避免双重征税协定中,规定了受益所有人享受税收协定待遇的条款,以及在国内明确了判定税收协定待遇申请人的“受益所有人”身份的原则和举证原则来规制第三国居民对税收协定的滥用,但是第三国居民滥用税收协定的避税行为仍有发生。在我国,近来对受益所有人滥用税收协定的规制虽取得一定的进展。
The agreement signed by China on the double taxation avoidance stipulates the principle that the beneficiary owner should enjoy the treatment of the tax treaties and the principle of “benefiting the owner” of the applicant who determines the treatment of the tax treaties within the country Regulate the abuse of tax treaties by residents of third countries, but tax avoidance by third-country residents abusing tax treaties still occurs. In our country, some progress has recently been made in the regulation of the abuse of tax treaties by the beneficiary owners.