跨国公司通过资本弱化和避税港进行避税已成为焦点。防止通过资本弱化进行避税的重点在于对利息扣除进行限定,或者将名义上由债权产生实际却是由股权产生的所得推定为股息加以课税,或者二者并用。多数国家实行安全港模式,对超过安全港界限的利息,不仅不允许作为费用扣除,而且将其重新归类为公司分配利润或股息,按股息的税率征收公司所得税和预提税。防止通过避税港进行避税的重点是建立受控外国公司的特别征税规则,即对实际上归属本国居民而在避税港设立的公司,对其利润归属于本国居民股东的部分,即使当年不分配,也不汇回本国,也要视同当年分配的股息与其它所得一并缴纳本国所得税,从而防止将利润往避税港转移。 Multinational corporations have become the focus of tax avoidance through capital weakening and tax havens. The key point of preventing tax avoidance through capital weakening is to limit the deduction of interest, or to tax the income derived from the actual creation of equity claims in nominal terms as dividends, or both. Most countries implement the safe harbor model. For interest rates exceeding the limits of safe harbor, not only the deduction of fees but also the reclassification of profits or dividends for companies should be allowed. Corporate income tax and withholding tax should be levied at the rate of dividends. The main focus of preventing tax avoidance through tax havens is the establishment of special tax rules for controlled foreign companies, that is, corporations established in tax havens that actually belong to their own residents, and those whose profits are vested in domestic resident shareholders, even in the current year , Nor repatriate their own country, but also treat their own income tax together with other income as dividends distributed in that year, thus preventing the transfer of profits to tax havens.