vxAnNqwbBg on "in the &quot"

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20096 eleventh volume third issue of 
 ink j the seven time Journal
JournalofSouthwestUniversityofPoliticalScienceLaw
June., 2009
VoLll
No.3
 this Code: 1001 - 2397 (2009) 03 - 0055 lO
 international tax treaties and domestic law to explore the relationship between 
 -- the Controlled Foreign Company tax system from the perspective of 
 Zhang Weibin 
 (Law School of Anhui Finance and Economics University, Anhui Bengbu 233030) 
 Abstract: for a long time, the relationship between international tax agreement and anti tax avoidance has been controversial. Is generally believed that. Tax treaties are superior to the domestic tax law; but, in order to prevent taxpayers tax treaty abuse of tax avoidance, this principle should not be absolute. The Controlled Foreign Company tax as an important tax anti avoidance measures, also produced the compatibility issues and tax treaty. From the practice of EU countries, point of view is not consistent. But the 2003OECD commentary makes clear a regulation, the two are compatible. Because our country stipulates the system, in the new enterprise income tax therefore, solve the compatibility also must face the problem. At the same time, in the "constitution" no provisions on the status of treaties in domestic law, China's "enterprise income tax law" fifty-eighth article should be improved. Keywords:
 tax agreement; Controlled Foreign Company; the European Union; the OECD Figure
: DF963
 document code: AIn order to avoid
 base company established in tax havens by Multi-National Corporation or low tax areas of the United States of America through the channel of tax avoidance, "Kennedy act" in 1962, the Controlled Foreign Company (Controlled
ForeignThe rules of
, all kinds of anti avoidance rules, to resist the harmful tax competition. However, tax agreement whether has the anti tax avoidance function, or even with this function, but on the whole, whether it contains some specific anti avoidance rules, thus their compatibility has been a controversial question 
Company, referred to as CFC) legal system is embodied in the "Internal Revenue Code" (Intemal
Revenue
Code) F segment. The so-called controlled outside. Therefore, how to clarify the relationship between the two countries is the urgent need to address the problem. 
's company, is defined by its residents directly or indirectly control of foreign public 
 division. Because CFC system can effectively limit the taxpayers for tax or tax avoidance, and the organization for economic cooperation and development (OECD) to be particularly recommended the, so that Germany, Canada, France, the more than 20 countries have formulated the controlled foreign >

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