税收协定视角下的我国对外直接投资研究
发布时间：2018-08-09 14:29
【摘要】：随着世界经济一体化的发展，各国都运用税收优惠政策支持和鼓励本国企业对外直接投资。2000年我党为拓展国民经济发展空间，促进世界经济共同发展，继“科教兴国”战略、“西部大开发”战略之后正式提出“走出去”战略，鼓励企业扩大对外投资规模。另外，在后金融危机时代，鼓励本国企业对外直接投资，加强各国之间的经济贸易联系也是保证经济稳定、健康发展的有效手段。 税收协定是缔约国政府间签署的具有法律约束力的协议，目的是为了促进缔约国之间的经济合作与人员交流。它能够保证跨国纳税人的海外投资、经营、劳务等所得避免双重征税、消除税收歧视；此外，还可以有效防范跨国纳税人偷税、漏税行为的发生，有助于公平、健康的国际税收秩序的形成。对外签署税收协定在鼓励我国企业“走出去”战略中扮演着非常重要的角色。目前，与美国、法国等发达国家采取关税优惠、所得税减免、抵免、延期纳税等多种优惠措施相比，我国在对外直接投资税收激励方面手段比较单一，亟待完善。金融危机改变了国际经济格局，后金融危机时代，通过税收调控促进我国企业“走出去”意义深远。但是，，我国促进对外直接投资的税收体系总体上缺乏规划，税收政策缺乏导向性，系统性。税收协定方面更是存在诸多问题，主要问题是税收协定的完善与更新没有及时向“引进来”与“走出去”相结合的国家战略转变，国内配套政策规定也未能与税收协定的规定同步。税收协定是维护国家税收权益和企业对外直接投资利益的重要法律保证。完善税收协定，不但为“走出去”企业创造了较为公平的境外税收待遇，也为企业在境外遇到税务纠纷时，提供了法律依据和运作机制。 深入研究对外签署税收协定如何影响我国企业对外直接投资决策，以及我国当前相关政策规定存在的问题及有效对策，对“走出去”战略的有效实施和我国国际税收政策、措施的合理调整具有重要的理论意义和实践价值。我国的对外直接投资发展经历了很长一段时间，相比于现在飞速发展的对外直接投资规模，我国相关税收政策却发展缓慢，税收协定只是其中很小的一部分。为了解决日益复杂的国际税收问题，保证我国“走出去”企业能够真正从中获益，促进我国经济的发展，我们应该立足于我国国情，建立实际、科学、完善的对外直接投资政策体系，为我国对外直接投资的发展提供良好的税收环境。
[Abstract]:With the development of world economic integration, all countries use preferential tax policies to support and encourage their enterprises' foreign direct investment. In 2000, in order to expand the space for the development of national economy and promote the common development of world economy, following the strategy of "rejuvenating the country through science and education", After the strategy of "developing the West", the strategy of "going out" was formally put forward to encourage enterprises to expand the scale of overseas investment. In addition, in the post-financial crisis era, encouraging the foreign direct investment of domestic enterprises and strengthening the economic and trade ties between countries is also an effective means to ensure the economic stability and healthy development. The tax treaty is a legally binding agreement signed by the governments of the contracting states to promote economic cooperation and personnel exchange among the contracting states. It can ensure that multinational taxpayers' income from overseas investment, operation, and labor services can avoid double taxation and eliminate tax discrimination. In addition, it can also effectively prevent the occurrence of tax evasion and tax evasion by transnational taxpayers, which is conducive to fairness. The formation of a healthy international tax order. The signing of foreign tax treaty plays a very important role in encouraging Chinese enterprises to go out. At present, compared with the developed countries, such as the United States, France and other developed countries, such as tariff preference, income tax reduction, credit, deferred tax payment and other preferential measures, our foreign direct investment tax incentives are relatively simple, and need to be improved. The financial crisis has changed the international economic pattern. In the post-financial crisis era, it is of far-reaching significance to promote Chinese enterprises to "go out" through tax regulation and control. However, the tax system of promoting foreign direct investment in our country lacks planning, and the tax policy lacks guidance and systematicness. There are even more problems in the area of tax treaties. The main problem is that the perfection and renewal of tax agreements have not changed into the national strategy of "bringing in" and "going out" in a timely manner. Domestic policy provisions also failed to synchronize with the provisions of tax treaties. Tax agreement is an important legal guarantee to safeguard the national tax rights and interests and the interests of enterprises' foreign direct investment. Perfecting the tax agreement not only creates a fair overseas tax treatment for the "going out" enterprises, but also provides the legal basis and the operating mechanism for the enterprises when they encounter tax disputes abroad. This paper deeply studies how the signing of tax agreements with foreign countries affects the decision of Chinese enterprises' foreign direct investment, as well as the existing problems and effective countermeasures in China's current relevant policies, the effective implementation of the "going out" strategy and the international tax policies of our country. Reasonable adjustment of measures has important theoretical significance and practical value. The development of China's foreign direct investment (FDI) has been going through a long period of time. Compared with the rapid development of foreign direct investment (FDI), the development of relevant tax policies in China is slow, and the tax agreement is only a very small part of it. In order to solve the increasingly complex international tax problem, to ensure that our "going out" enterprises can really benefit from it and to promote the development of our economy, we should base ourselves on the national conditions of our country and establish reality and science. Perfect foreign direct investment policy system provides a good tax environment for the development of China's foreign direct investment.
【学位授予单位】：吉林财经大学
【学位级别】：硕士
【学位授予年份】：2012
【分类号】：F812.42;F832.6
本文编号：2174375
[Abstract]:With the development of world economic integration, all countries use preferential tax policies to support and encourage their enterprises' foreign direct investment. In 2000, in order to expand the space for the development of national economy and promote the common development of world economy, following the strategy of "rejuvenating the country through science and education", After the strategy of "developing the West", the strategy of "going out" was formally put forward to encourage enterprises to expand the scale of overseas investment. In addition, in the post-financial crisis era, encouraging the foreign direct investment of domestic enterprises and strengthening the economic and trade ties between countries is also an effective means to ensure the economic stability and healthy development. The tax treaty is a legally binding agreement signed by the governments of the contracting states to promote economic cooperation and personnel exchange among the contracting states. It can ensure that multinational taxpayers' income from overseas investment, operation, and labor services can avoid double taxation and eliminate tax discrimination. In addition, it can also effectively prevent the occurrence of tax evasion and tax evasion by transnational taxpayers, which is conducive to fairness. The formation of a healthy international tax order. The signing of foreign tax treaty plays a very important role in encouraging Chinese enterprises to go out. At present, compared with the developed countries, such as the United States, France and other developed countries, such as tariff preference, income tax reduction, credit, deferred tax payment and other preferential measures, our foreign direct investment tax incentives are relatively simple, and need to be improved. The financial crisis has changed the international economic pattern. In the post-financial crisis era, it is of far-reaching significance to promote Chinese enterprises to "go out" through tax regulation and control. However, the tax system of promoting foreign direct investment in our country lacks planning, and the tax policy lacks guidance and systematicness. There are even more problems in the area of tax treaties. The main problem is that the perfection and renewal of tax agreements have not changed into the national strategy of "bringing in" and "going out" in a timely manner. Domestic policy provisions also failed to synchronize with the provisions of tax treaties. Tax agreement is an important legal guarantee to safeguard the national tax rights and interests and the interests of enterprises' foreign direct investment. Perfecting the tax agreement not only creates a fair overseas tax treatment for the "going out" enterprises, but also provides the legal basis and the operating mechanism for the enterprises when they encounter tax disputes abroad. This paper deeply studies how the signing of tax agreements with foreign countries affects the decision of Chinese enterprises' foreign direct investment, as well as the existing problems and effective countermeasures in China's current relevant policies, the effective implementation of the "going out" strategy and the international tax policies of our country. Reasonable adjustment of measures has important theoretical significance and practical value. The development of China's foreign direct investment (FDI) has been going through a long period of time. Compared with the rapid development of foreign direct investment (FDI), the development of relevant tax policies in China is slow, and the tax agreement is only a very small part of it. In order to solve the increasingly complex international tax problem, to ensure that our "going out" enterprises can really benefit from it and to promote the development of our economy, we should base ourselves on the national conditions of our country and establish reality and science. Perfect foreign direct investment policy system provides a good tax environment for the development of China's foreign direct investment.
【学位授予单位】：吉林财经大学
【学位级别】：硕士
【学位授予年份】：2012
【分类号】：F812.42;F832.6
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