论我国资本弱化税制完善3.docVIP

论我国资本弱化税制的完善 （硕士论文摘要） 资本弱化，是指企业目的，在融资方式的选择上，降低的比重提高的比重，从而造成企业的资本结构中的比重大大超过的比重。资本弱化 Study on the Improvement of Chinese Thin Capitalization Legal Rules (Abstract) Major： JM： Economic Law Author： Tutor： investment, hidden capitalization or hidden stock, which refers that a corporation regards as its exclusive or main purpose and it adopts an approach that a corporation’s debt to equity ratio exceeds certain limit, using an excessive proportion of debt capital financing in order to avoid income tax payable. Comparing with transferring pricing tax, registration tax avoidance and other common methods, this approach is a more subtle form and a greater harm which not only causes a huge loss of revenue, but also affects the actual results to attract foreign investment in practice and it would be difficult to detect and monitor thin capitalization. As an important tax avoidance, thin capitalization is so increasingly concerned by most countries that many rules are made to restrict thin capitalization. In research area, taking an overview of the current study of the domestic and international ax laws, we can find that their study is from the following aspects: research on the specific system of thin capitalization, the practice and comparative study on thin capitalization. Although the researches are more, they lack of theoretical analysis of thin capitalization from the perspective of law. Under these circumstances, thin capitalization is studied from a new perspective that compounds the theories of ax law and economic law. Accordingly, it is emphasized to take thin capitalization as the object of the study, tax law and economic law as supporting theories and the improvement of Chinese thin capitalization legal rules as the thoughts of the study in this paper. There are three parts in this paper: In the first part, the theoretical basis of thin capitalization is studied from the perspective of tax law and economic law, an