一、资本过少税制的内容所谓资本过少税制,就是把企业从股东(特别是外国股东)处借入的资金中超过资本一定限额的部分,从税收角度上视同股本(资本),并规定这部分的借款利息不得列入成本以防企业避税。所以,它属于反避税的税制措施。其主要内容是:外国公司向其外国子公司(包括分公司)等只投入少量资本,而以贷款方式提供大量资金,并收取利息,这样,就可以使该子公司等在所在国的应纳税所得减少,实行避税。为了防止以该种方式减少所得进行避税,在一定条件下,将其部分借款视同资本进行税收处理。欧美各国很早就注重了资本过少的问题,并逐步 First, the content of the capital deficit tax system The so-called capital deficit tax system, is the part of the capital borrowed from the shareholders (especially foreign shareholders) in excess of a certain amount of capital from the tax point of view as equity (capital), and provides Interest on this part of the loan shall not be included in the cost of avoiding tax avoidance. Therefore, it is anti-tax avoidance tax measures. Its main content is: foreign companies to their foreign subsidiaries (including subsidiaries) and so only a small amount of capital, and loans to provide large amounts of money and interest, so that the subsidiary can be taxed in the country where the tax Income reduction, the implementation of tax avoidance. In order to prevent tax avoidance in this way to reduce the income, under certain conditions, some of its borrowings as capital for tax treatment. The countries in Europe and the United States have paid great attention to the issue of too little capital and have gradually taken steps