对于如何处理与国有、集体企业改制①相关的所得税问题,由于国家税务总局先后下发的一系列文件②没有做出统一和明晰的指导意见,导致税务机关对企业改制过程的主动介入缺乏必要的法律依据,结果是相关的所得税问题难以得到规范化解决,出现了税源流失或重复课税的现象,在一定程度 As for how to deal with the income tax related to the restructuring of state-owned and collective enterprises, ① the series of documents successively issued by the State Administration of Taxation did not make unified and clear guidance, which led to the lack of necessary tax authorities’ active intervention in the process of enterprise restructuring Legal basis, the result is related to the issue of income tax is difficult to be standardized, there has been a tax drain or double tax phenomenon, to some extent