目前我国学者对股东征税制度的研究还很少,但是随着股份制改革的逐步推进和完善,股东征税制度的研究显得日益重要。本文在对英国和西班牙股息、资本利得征税制度比较分析的基础上,以国际税收竞争理论为基础对我国相关税制改革提出了两点建议:一是对我国居民公司的非居民个人股东长期投资获得的股息免税,而对居民个人股东长期投资获得的股息采用归集抵免制来消除重复征税;二是尽快开征独立的资本利得税,同时改革证券交易印花税。 At present, there are few researches on the taxation system of shareholders by Chinese scholars. However, with the gradual progress and improvement of the shareholding system reform, the study on the tax system of shareholders becomes more and more important. Based on a comparative analysis of the taxation system of dividends and capital gains in Britain and Spain, this paper puts forward two suggestions on the reform of China’s tax system based on the theory of international tax competition: First, the long-term investment in non-resident individual shareholders of Chinese resident companies The dividends obtained are exempt from tax. Dividends obtained through long-term investments of individual shareholders of residents are tax-deductible to eliminate double taxation. Second, an independent capital gains tax is levied as soon as possible, and the stamp duty on securities transactions is also reformed.