税收饶让,也称作税收饶让抵免(Tax Sparing Gredit),是指一国政府(居住国政府)对本国纳税人在国外投资得到投资所在国(收入来源国)减免的那一部分税收,视同已经缴纳,同样给予抵免待遇。税收饶让的目的是在运用抵免法消除国际重复征税的条件下,保证资金输入国(一般多为发展中国家)为吸收外国投资所做出的种种税收减让得到真正落实,税收优惠得到充分发挥。因此,税收饶让常常成为两个国家尤其是发展中国家和发达国家在签订税收协定中的一个中心问题,一些发展中国家甚至把税收饶让提供与否视为签订税收协定的首要意义。但是,纵观世界各有关国家所签订的税收协定,税收饶让又各有不同类型,饶让抵免方法也各有差别。因此,对税收饶让的进一步分析考察有助于我们对税收饶让实质及其作用认识的更趋深化。 Tax Sparing Gredit, also known as Tax Sparing Gredit, refers to the part of a country’s government (country of residence) that exempts its taxpayers from investing in a foreign country (source country) Deemed to have been paid, the same to give credit treatment. The purpose of tax sparing is to ensure that all kinds of tax concessions made by foreign-invested countries (mostly developing countries) to attract foreign investment are truly implemented under the condition of eliminating international double taxation by applying the credit method. Tax incentives Get full play. Therefore, the tax sparing often becomes a central issue in the signing of tax treaties between two countries, especially developing and developed countries. Some developing countries even regard the provision of tax revenue as the primary significance of signing a tax treaty. However, looking at the tax treaties signed by all the countries in the world, there are different types of tax levies, and there are also differences in the methods of giving credit. Therefore, the further analysis and study of tax sparing will help us to deepen our understanding of the essence and role of tax sparing.