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欧盟将BEPS项目作为其加速实现欧洲税收一体化的工具,因此对落实BEPS项目极为积极。BEPS项目在欧盟落地是分两个层面同时进行的:一是在欧盟层面,由欧盟相关机构发布各项“硬法”和“软法”措施,督促欧盟成员国落实BEPS项目成果;二是在欧盟二十八个成员国层面,由各成员国分别制定国内法来落实BEPS项目。对于我国赴欧投资企业而言,BEPS项目不仅会造成其税收合规成本上升、对税收的不确定性增加和税收争议增多,还会影响其投资架构、交易安排和在欧盟的竞争力。
The EU has taken the BEPS project as its tool to accelerate the integration of European tax revenues and is therefore extremely active in implementing the BEPS project. BEPS project in the EU landing is carried out at two levels at the same time: First, at the EU level, issued by the relevant EU agencies “hard law ” and “soft law ” measures to urge EU member states to implement the BEPS project results ; The other is that at the level of 28 member states of the EU, each Member State formulates its own domestic laws to implement the BEPS project. For China’s investment enterprises in Europe, the BEPS project will not only increase its tax compliance costs, increase tax uncertainty and tax disputes, but also affect its investment structure, trading arrangements and competitiveness in the EU.