The Anti-Tax Evasion Regimes of the Controlled Foreign Corporation

• Main Authors: Huan Shen, 沈煥
• Other Authors: Jinn-Der Chang
• Format: Others
• Language: zh-TW
• Published: 2012
• Online Access: http://ndltd.ncl.edu.tw/handle/75916576594312169137

碩士 === 朝陽科技大學 === 會計所 === 100 === In the advent of internationalization for the global economy, internationally anti tax evasion system has become issue that the world major capital export countries would focus upon. Whereas the income tax system for CFC (Controlled Foreign Corporation) is the standardized international tax benchmark for major advanced countries and this is just one of approaches in preventing from tax evasion. Although there have been some variations in the standard’s contents for all nations involved, nonetheless, the intent of preventing from improper tax evasion and activities, to ensure national tax bases not being encroached upon, to reach the objective of fair and equitable tax levy, in these areas, all the nations involved have been relatively consistent. During recent years, our nation has smoothly developed the technologically intensive and capital intensive industries, and we have gradually migrates toward one of the net capital exporter countries. Although our nation had implemented profit-oriented enterprise transferring and pricing setting compliance system since 2004, still, there is still room for improvement in the area like preventing the CFC tax shelter delayed effects. Hence under the ideal of tax base’s fairness and neutrality, it is a quite pressing matter to strengthen our standards established for CFC income tax system. This research intends to start with exploring the current status of our tax system. And it also references the pros and cons from the systems in other nations and expects to engage from the perspectives of both the tax theories and practicality. There will be recommendations which seek for systems conducive to the establishing FCC tax system for our nation with the intent to complement the inadequacies stemmed from domestic income taxes.