随着越来越多的区域贸易协定将投资纳入其统辖范畴,双重征税、税收歧视、税收逃避和有害税收竞争等所得税问题的解决对于促进区域投资自由化无疑具有重要意义。目前,区域贸易协定并不涉及其成员的所得税制度问题,双重征税和税收歧视主要依靠成员间的双边税收协定来解决。但是,双边税收协定对于双重征税和税收歧视的消除并不彻底,也难以应对区域内的税收逃避和税收竞争问题。因此,区域贸易协定的成员需要在国内法、税收协定和区域安排等方面做进一步的努力。 With more and more RTAs including investment in their jurisdictions, the solution to the problem of income tax such as double taxation, tax discrimination, tax evasion and harmful tax competition will undoubtedly be of great significance to the promotion of regional investment liberalization. At present, the RTA does not cover the income tax system of its members. Double taxation and tax discrimination mainly depend on the bilateral tax treaties among the members. However, bilateral tax treaties have not completely eliminated double taxation and tax discrimination, and have also been unable to cope with the problems of tax evasion and tax competition in the region. Therefore, members of RTAs need to make further efforts in domestic law, tax treaties and regional arrangements.