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“一带一路”的背景下,企业在国际经济交往中面临更大的融资需求,为达到避税目的,更加倾向于债务性融资方式,基于此增加的资本弱化行为将侵蚀居民国税基,扰乱市场经济秩序。企业资本弱化的税收规制当前存在立法不完善、债务资本比例界定模糊等问题,需要明确规制方法与原则,加强国际税收合作,以完善资本弱化的税收规制路径,维护我国税收主权与利益。
Under the background of “One Belt and One Road”, enterprises are facing more financing needs in international economic exchanges. For the purpose of tax avoidance, they are more inclined to adopt debt financing methods. The capital weakening based on this will erode the resident tax base and disturb Market economy order. The tax regulation of weakening corporate capital currently has some problems, such as imperfect legislation and fuzzy definition of debt-to-capital ratio. It is necessary to regulate the methods and principles clearly and strengthen international tax cooperation so as to perfect the tax regulation path of capital weakening and safeguard China’s tax sovereignty and interests.