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nited States In tax law system of The United States, the fiscally transparent entity is including limited liability partnership, the general partnership, limited liability pany, mon investment trust, grantor trust. In tax law system of Japan On Japanese tax law study, the fiscally transparent entities is including the “special purpose trust”, “special purpose panies”, “investment business limited partnership”, Japanese silent partnership( called ‘tokumei kumiai’ ?? ?? ) et cetera. Back to Table of Contents 5/11/2022 4 Ⅰ . Introduction (Problem Awareness) click Ⅱ . Formation amp。 Rules for Transparent Entity Ⅳ . The Development of The Theory of The Transparent Entity Theory of “Trialism of Taxpayer classification” Ⅴ. Main Problems of Partnership Taxation System in China Ⅵ . Conclusion Awareness of Problem 5/11/2022 5 Private law purpose ?To promote the development of SME( Small and Medium Enterprises) in China, ( ?? ?? ?? ?? ) ?To create a vehicle of economic activities accord with the demands of the Chinese market economy. ( ?? ??? ??? ) Tax purposes ?To achieve fairness on tax law, and creating the equal tax environment between SME and other enterprises。s Existing Partnership Taxation System Promote the development of the Small and Medium scale enterprises? Whether the Chinese current partnership enterprise ine tax law system is in pliance with the private law purpose and tax law purpose or not? Next Ⅱ Formation amp。 The Development of Legislation In China NEXT 2. The Characteristics and The Structure of Partnership Entity In Business Organization Law System (1) The Type of Partnership Entity (2) The Partner (3) The Establishment of partnership (4) Allocation of the profits in Partnership (5) The share Transfer of interest holder The legal form of Enterprise In Modern Chinese private law system 5/11/2022 8 Created by Civil law Public Institutions, Social Organizations Created by business law – type one: the legal form of enterprise with Chinese Characteristic ?? ??? ?? ?? ?stateowned enterprises(1988), collectivelyowned enterprise(1991), private enterprises(1988) ?Foreigninvested enterprises(1980, 1988, 1986) (such as Sinoforeign joint venture, Sinoforeign joint cooperative ventures, solely foreignowned enterprises ). Created by business law – type two: general sense of the classification(after 1993 market