Establishing a simple, easy-to-follow, easy-to-operate and time-sensitive tax policy is the basic prerequisite for strengthening the income tax supervision of non-resident enterprises. In order to ensure the strictness, pertinence, operability and guidance of policies in practical application, the tax policies or management measures of non-resident enterprises should be more detailed, standardized and specific. It is necessary to clarify the tax liability period for non-residents to obtain the return of technology use rights in kind or labor services, debt restructuring between affiliated enterprises and other businesses. Define the tax period of dividend income of non-resident enterprises, otherwise it will easily lead to confusion between the tax period of dividend income of non-resident enterprises and the confirmation date of dividend income. At present, the tax collection and management system (CTAIS system) can basically meet the tax collection and management needs of most non-residents to participate in tax declaration (including self-declaration, entrusted agent declaration or payer withholding). However, as a special case in the equity transfer of non-resident enterprises, that is, transferring two or more non-resident shares and completing transactions abroad, there are still defects in the declaration system, collection and management system, tax recovery and so on. It is suggested that the relevant modules of withholding income tax by non-resident enterprises should be added to the declaration system, or the scope of withholding and remitting obligations of domestic enterprises should be expanded, so that grass-roots tax authorities can operate and implement it easily in practical work under the principle of giving consideration to simple operation and improving efficiency.
(2) Strengthen information collection and lay a solid foundation for information work.
Incorporate the tax collection and management of non-resident enterprises into the daily management of the responsibility area, while improving the quality of tax service, strengthen the tax management of non-resident enterprises, fully understand the tax sources, and do not wait for the tax sources to declare themselves, but take the initiative to attack various tax sources and reduce tax risks. By the administrator to enter the area of non-resident enterprises to conduct a comprehensive special field investigation, so that there is no blind spot in the collection and management; Establish and improve the taxpayer information base and pre-registration system; In-depth investigation of non-resident enterprises set up institutions in China, but whether there is information on taxable income from the jurisdiction; Focus on taxable payment items, payment amount, payment object, institutional nature of payment object and relevant contract documents signed by domestic institutions and withholding agents, collect and record such items, and establish enterprise foreign exchange payment ledger.
(3) Enjoy internal and external information and expand the sources of information and intelligence.
1. On the basis of on-site inspection and verification by the manager, strengthen the internal information exchange of suspicious or abnormal payment items step by step to plug the loopholes. At the same time, it is necessary to carry out special assessment and inspection of non-resident enterprise income tax from two levels: withholding agents and domestic institutions. Based on the combination of analysis and inspection, desk evaluation and field evaluation, daily tax assessment and annual final settlement, evaluation and inspection, evaluation and inspection and afterwards rectification, we will focus on solving the problem of false declaration information, effectively resolve the difficulties, doubts and blind spots in tax collection and management, give full play to the effect of tax assessment, give full play to the crackdown of inspection, and earnestly safeguard the fairness of tax collection and management.
2. In view of the fact that the non-resident tax business is complex, chaotic, scattered and changeable, many transactions take place overseas, and a large number of non-resident enterprises lack institutions and places in China, we will focus on strengthening the construction of information exchange channels for non-resident enterprises, strengthening the means of collection and management, realizing effective tax source monitoring, and strengthening information exchange inside and outside the system. Tax authorities should strengthen information exchange with foreign exchange management, development and Reform Commission, customs, public security, banking supervision, industry and commerce, foreign trade and economic cooperation and other relevant departments, timely grasp the basic information and changes of non-resident enterprises, strengthen international information exchange, and establish a systematic and strict tax cooperation and protection network for non-resident enterprises. The tax authorities should regularly go to the Foreign Trade and Economic Cooperation Bureau to obtain information on changes in equity of enterprises, regularly go to the Municipal Administration of Foreign Exchange to obtain data information on enterprise technology import and export contracts, intangible assets sales, foreign debts, etc., and go to the accounting department of the People's Bank of China to obtain information on interest income from offshore deposits of non-resident enterprises of commercial banks, plug loopholes and control tax sources.
(four) to enhance the professional level, increase policy propaganda.
To strengthen the training of cadres' professional knowledge and operational skills internally, one is to broaden the horizons of tax cadres theoretically, and the other is to update management concepts and learn from advanced management experience abroad or at home and abroad to improve the tax management level of cadres to non-resident enterprises. Externally, in view of the fact that investors and corporate legal persons are unfamiliar with tax policies, have a weak sense of paying taxes and evade taxes maliciously, tax officials should strengthen policy propaganda and tax guidance for non-resident enterprises. Through the development of service platforms such as "heart-to-heart talk between tax enterprises", "interpretation of tax law", "visit to key enterprises", "tax coordinator system" and "appeal collection system", we will intervene in advance, and strengthen peer-to-peer communication through various forms such as on-site tax payment, on-site consultation, on-site political inquiry and on-site problem solving, and promptly accept and respond to tax-related appeals of non-resident enterprises; Carry out "customer-oriented" services, establish a green channel for key and complex matters, handle special and urgent matters, move forward the links of tax service and tax management appropriately, and combine them with risk management to help enterprises fully understand policies, improve taxpayers' compliance, reduce tax-related risks and fully enjoy tax incentives.