近年来中国与韩国、日本和俄罗斯的双向投资呈增长趋势。中国、韩国、日本、俄罗斯(以下简称“东北亚四国”)投资增长的法律原因主要体现于双边投资协定对投资的保障以及税收制度的促进作用。为避免税收对投资的阻碍作用,东北亚四国应当加强税收协定协调和反避税合作。一方面,中韩以及中日可以考虑参照新修订的《中俄双边税收协定》,适当降低双边的限制税率,以利于中国与韩日的双边经贸投资。另一方面,东北亚四国在跨境税收协调与合作中应当共同打击税收协定滥用行为以保护各国税基。考虑到“受益所有人”概念的局限性以及利益限制规则的复杂性,东北亚四国在今后签订或修订税收协定时,应当以主要目的测试条款为主要的反协定滥用规则。 In recent years, bilateral investment between China and South Korea, Japan and Russia has been on the rise. The legal reasons for the growth of investment in China, South Korea, Japan and Russia (hereinafter referred to as “Northeast Asia and China ”) are mainly reflected in the protection of investment by Bilateral Investment Agreements and the promotion of the tax system. In order to avoid the impeding effect of tax on investment, the four countries in Northeast Asia should step up the coordination of tax treaties and anti-tax avoidance cooperation. On the one hand, China and South Korea as well as Japan and China can consider referring to the newly revised “China-Russia Bilateral Tax Agreement” and appropriately reduce the bilateral restriction tax rate to facilitate bilateral economic and trade investment between China and South Korea and Japan. On the other hand, the four countries in Northeast Asia should jointly combat the abuse of tax treaties in cross-border tax coordination and cooperation in order to protect the tax bases of all countries. Taking into account the limitations of the concept of “beneficiary owner” and the complexity of the rules of interest limitation, the four countries in Northeast Asia should, when signing or amending the tax treaties in the future, adopt the main purpose test clause as the main anti-treaty abuse rule.