我国涉外企业所得税改革的方向,是合并中外合资经营企业所得税和外国企业所得税(以下简称两税合并)。前段时期,对这个问题的研究已取得突破性进展,两税合并势在必行。现在,为促成新税法尽快出台,有必要重新认识两税合并的意义。一、两税分离不适应现行法律制度的要求两税分离制的存在有其客观的历史条件。在我国实行对外开放政策的初期阶段,由于原 The direction of the reform of the income tax of foreign-related enterprises in China is the income tax on the merger of Chinese-foreign equity joint ventures and the income tax on foreign enterprises (hereinafter referred to as the “two-income tax merger”). Some time ago, the research on this issue has made breakthrough progress, and the merger of the two taxes is imperative. Now, in order to promote the new tax law as soon as possible, it is necessary to re-understand the significance of the merger of the two taxes. First, the separation of two taxes do not meet the requirements of the current legal system The existence of two tax separation system has its objective historical conditions. In the initial stage of China’s policy of opening to the outside world, due to the original