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根据《中华人民共和国外商投资企业和外国企业所得税法》(以下简称(《外税法》)的规定,按照注册地与管理控制机构所在地确定的居民企业负有全面纳税义务。因此,对于总机构设在我国的外商投资企业,需就其境内外所得在我国申报缴纳企业所得税。实践执行中,外商投资企业办理境外所得完税事宜时,通常对税款的计算及申报缴纳等问题存在困惑, 增加了其纳税遵从成本和可能承担的纳税风险。为此,笔者对外商投资企业境外所得的所得税相关政策进行梳理,以期提高企业的纳税遵从度。
According to the “Law of the People’s Republic of China on Income Tax of Foreign-Funded Enterprises and Foreign Enterprises” (the “Foreign Tax Law”), resident enterprises that are identified according to the place of incorporation and the place where the regulatory control agency is located bear the full tax liability. Therefore, Foreign-invested enterprises in China need to declare and pay corporate income tax on their domestic and overseas incomes. In practice, foreign-invested enterprises often have problems confronting the calculation and declaration of taxes when applying for the tax payment of overseas income. Its tax compliance costs and possible tax risk.To this end, the author sorts out the income tax related policies of foreign-invested enterprises abroad, with a view to improve their compliance with tax payment.