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为促进缔约双方相互间的股权投资,双边税收协定往往要求投资东道国对跨国股权投资的收益即跨国股息,进行预提税率的限制。为体现税收中性和税负公平的原则,同时将外资政策体现在税收协定中,东道国往往区分直接投资和间接投资,并对由此取得的股息收入进行程度不同的税率限制。我国作为全球最重要的投资东道国之一,亟须按照区分征税的理论来完善税收协定相应条款的规定,以发挥税收的宏观调控功能,最大限度地维护我国的税收和投资利益。
In order to promote the mutual equity investment between the two parties, bilateral tax treaties often require the host country to reinvest its cross-border dividends on the proceeds of its transnational equity investment and to impose restrictions on the rate of withholding tax. In order to reflect the principle of tax neutrality and tax burden fairness, at the same time, embody the foreign investment policy in the tax treaties. The host country often distinguishes between direct investment and indirect investment, and limits the tax income to different levels. As one of the most important investment host countries in the world, our country needs to perfect the provisions of the corresponding provisions of the tax treaties in accordance with the theory of tax distinction so as to give play to the macro-control function of tax revenue and maximize the tax and investment interests of our country.