目前国际上对信托征税的理论有二种观点:一种是信托实体论,另一种是信托载体论,日本原则上是以信托载体论作为课税理论基础的,即认为信托课税并非对“信托本身”课税,而是对“信托契约行为”及“遗嘱信托行为”的所得课税,因此,并未设立专门的“信托税法”,只是将对信托征税规定分散于相关的税法之中,现分别税种介绍如下。 At present, there are two kinds of theories about the taxation of trust in the world: one is the trust entity theory and the other is the trust carrier theory. In principle, Japan regards the trust carrier theory as the taxation theory, that is, trust taxation is not Taxing the “trust itself”, but rather the income tax on “trust contractual acts” and “testamentary trusts”. Therefore, no special “trust tax law” has been set up, except that the taxation provisions on trusts are dispersed in the relevant Among the tax laws, the tax categories are as follows.