关于外籍人员担任中国境内企业高层管理职务取得的工资薪金所得纳税义务及计算缴纳个人所得税问题，始终成为涉外税务工作人员业务讨论的焦点。有人认为，高层管理人员境内支付的工资薪金，应同样按照所得来源地作为惟一判定标准确定其纳税义务。即在一个纳税年度中在中国境内 The tax liability of foreigners serving as a member of the top management of enterprises in China and the calculation and payment of personal income tax have always been the focus of the discussions on the business of tax officers in foreign countries. Some people think that the wages and salaries paid by senior management personnel should be based on the same source of income as the sole criterion for determining their tax liability. That is, in a tax year in China