对涉外税收理论与实践的一些思考李达昌，曹萍一、对涉外税收范畴的理论思考我国理论界对涉外税收范畴的认识由于界定依据不同而存在不同观点。一是以纳税主体的涉外性为依据，认为涉外税收是国家直接以外商投资企业、外国企业单位及个人为纳税人的各种税收；二是以课税对... Some Thoughts on Theory and Practice of Tax Revenue Concerning Foreign Countries LI Da-Chang, CAO Ping-Yi A Theoretical Reflection on the Category of Foreign Tax Revenue The understanding of the tax scope of foreign-related tax in our country has different viewpoints because of different definition basis. First, on the basis of the foreign-related nature of the taxpayers, foreign-related taxes are regarded as taxes of various kinds that are directly invested by the state with foreign-invested enterprises, foreign enterprises and individuals as taxpayers;