随着我国企业改革的逐步深入 ,特别是我国加入WTO后 ,目前所实行的内外资企业所得税法有悖于国际惯例 ,已不能适应形势所需 ,实现内外税合并已成为当前税制改革的必然。本文就“两法合并”应遵循的原则 ;税种名称和纳税义务人的确定 ;税率的选择和确定 ;税基的确定 ;税收优惠的确定等“两法合并”后的若干核心问题进行了具体地探讨 ,并提出了相关的对策措施 With the gradual deepening of the reform of our country’s enterprises, especially after China’s accession to the WTO, the income tax laws of domestic and foreign-funded enterprises that are practiced now are contrary to the international practice and can no longer meet the needs of the situation. To achieve the integration of domestic and foreign taxes has become an inevitable result of the current tax reform. In this paper, the “two laws should be followed by the merger,” the principle of tax name and taxpayers to determine; the choice and determination of tax rates; tax base to determine; tax incentives to determine the “merger of the two laws” a number of core issues after the specific Explore, and put forward the relevant countermeasures