itax─苹果公司的国际避税结构和双重不征税问题（1）(下)
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内容提要：the aim of this article is twofold.first,it analyses the international tax structure of apple and investigates how it achieved the double non-taxation of us $44billion.the analysis reveals that the us government has knowingly facilitated the avoidance of foreign income tax by its multinational enterprises (mnes),thus creating double non-taxation.it also highlights the structural issues of domestic and international tax rules that enable the creation of double non-taxed income.secondly,the article reviews the possible responses of both the residence and source countries to apple?s tax avoidance structure,and argues that two issues are important in the design of effective solutions to the problem.first,the application of the enterprise doctrine—under which a corporate group under the common control of a parent company is treated as one single entity—is more likely to produce effective measures to tackle mnes'tax avoidance transactions.secondly,the increase in transparency,in particular a properly designed country-by-country reporting regime,would be a much needed weapon for tax authorities which at present suffer from information asymmetry in the tax avoidance battle with mnes.
the aim of this article is twofold.first,it analyses the international tax structure of apple and investigates how it achieved the double non-taxation of us $44billion.the analysis reveals that the us government has knowingly facilitated the avoidance of foreign income tax by its multinational enterprises (mnes),thus creating double non-taxation.it also highlights the structural issues of domestic and international tax rules that enable the creation of double non-taxed income.secondly,the article reviews the possible responses of both the residence and source countries to apple?s tax avoidance structure,and argues that two issues are important in the design of effective solutions to the problem.first,the application of the enterprise doctrine—under which a corporate group under the common control of a parent company is treated as one single entity—is more likely to produce effective measures to tackle mnes'tax avoidance transactions.secondly,the increase in transparency,in particular a properly designed country-by-country reporting regime,would be a much needed weapon for tax authorities which at present suffer from information asymmetry in the tax avoidance battle with mnes.