鸦片战争之后,西方各国在华侨民不断增加。在军事、外交和传教人员之外,还有大量侨民长期寓居中国,通过设厂投资、商业服务、自由职业等方式获利谋生。西方各国外侨在中国借治外法权及租界壁垒,拒绝向中国政府缴纳印花税、营业税、所得税等各类税捐,导致中国税务行政长期难及于外侨。关税自主运动的重点在于税权自主及税率调整,并未同步解决外国企业及侨民在华纳税问题。到1936年,南京国民政府正式开征所得税,再次引发各界对中外税收平权问题的集中讨论。外侨是否缴纳所得税,不仅关系税权税源,也直接影响到国内商民的纳税意愿。中国政府、民间社会及西方各国间围绕租税主权、税负公平、条约体系等问题展开激烈讨论与外交交涉。国民政府虽经努力,但仍难在税务行政范畴内解决问题,根本出路还在于中国与西方条约国家外交政治关系的重构。 After the Opium War, Western countries continued to increase their overseas Chinese. In addition to the military, diplomatic and missionary personnel, there are also a large number of expatriates who live in China for a long time and make profits by making investments in factories, commercial services and freelance jobs. In Western China, foreigners refuse to pay stamp duties, business tax and income tax to the Chinese government due to foreign monopoly power and concession barriers in China, resulting in the long-term difficulty of Chinese tax administration over foreigners. The focus of the tariff autonomy movement lies in the autonomy of tax rights and the adjustment of tax rates. The problem of taxation of foreign enterprises and diasporas in China is not solved simultaneously. By 1936, the Nanjing National Government formally introduced income tax, once again arousing public discussion on the issue of the right of taxation between China and other countries. Whether the aliens pay income tax, not only related to the tax source of tax revenue, but also directly affect the tax will of domestic businessmen. The Chinese government, civil society and all Western countries have heated discussions and diplomatic representations on issues such as tax sovereignty, fair tax burden and treaty system. Although the Nationalist government has tried its best, it is still difficult to solve the problem within the scope of tax administration. The fundamental solution lies in the reconstruction of the diplomatic and political relations between China and the treaty countries in the West.