本文探讨了中国在“典型三角案”下进行所得税收抵免时如何适用相关税收协定的问题。认为当中国作为跨国纳税人的居民国进行抵免时,应当按照所得的归属确定相应所得在税收协定上的抵免义务;当中国作为常设机构所在地国进行抵免时,应比较其分别与所得来源地国和居民国缔结的税收协定,以该所得规定较低的预提税税率来计算可抵免境外所得税税额。 This article explores how China applies the tax treaties when it comes to income tax credits under the “Typical Triangle Case.” When China as a resident of multinational taxpayers to carry out credit, should be in accordance with the ownership of the income to determine the corresponding tax credit agreement on the obligation to offset; when China as a permanent body in the country of credit should be compared with their income and income The tax agreement concluded between the country of origin and the country of residence calculates the amount of the tax that can be credited against the income tax as an income tax with a lower withholding tax rate.