一、案例简述1992年9月,日本B、C两家外资企业出资组建境内某服装A公司,其中B公司投资比例90%,C公司投资比例10%。A公司主要经营高档织物面料的织造和整理加工,国标行业属于机织服装制造行业,有自营和代理进出口业务。A公司成立当年即进入获利年度,开始享受“两免三减半”优惠。2010—2014年期间,A公司与香港D公司、E公司签订佣金协议,约定D公司、E公司负责为其扩展 I. Brief Description of Case In September 1992, two foreign-funded enterprises B and C in Japan invested to set up a garment company A in China, of which, B Company invested 90% and C Company invested 10%. A company mainly engaged in high-end fabric weaving and fabric processing, GB industry is a woven garment manufacturing industry, import and export and self-employed business. A company was established that year into the profit-making year, began to enjoy “two exemptions and three halves ” discount. During 2010-2014, Company A entered into a commission agreement with Company D and Company E in Hong Kong, stipulating Company D and Company E being responsible for their expansion