一个时期以来,我国为引进外资相继制定了一系列针对外商投资税收优惠的法律法规。但随着经济形式的发展变化,外资超国民待遇的税收征管制度制约了我国经济转型、产业结构升级目标的实现。现从法理角度,分析了外资税收优惠制度存在的弊端。 Since a certain period of time, our country has successively formulated a series of laws and regulations on tax incentives for foreign investment in order to attract foreign investment. However, with the development and changes in the economic form, the system of tax collection and administration over the national treatment of foreign capital has restricted the realization of the objective of economic restructuring and industrial upgrading in our country. From the perspective of jurisprudence, we analyze the shortcomings of foreign tax preference system.