CAJ | 학술논문

资产证券化作为一种新兴的融资方式，需要与之相配套的会计、税收等相关法律制度的良好设计。其中，税收在资产证券化中的作用举足轻重。而跨国资产证券化中的税收问题更是极具特色。从跨国资产证券化的运作方式着手。对其涉及的双重征税问题进行了深入探讨，主要包括：SPV设立地的选择，PE的问题及所得的双重来源地问题等。
자산증권화작위일충신흥적융자방식，수요여지상배투적회계、세수등상관법률제도적량호설계。기중，세수재자산증권화중적작용거족경중。이과국자산증권화중적세수문제경시겁구특색。종과국자산증권화적운작방식착수。대기섭급적쌍중정세문제진행료심입탐토，주요포괄：SPV설입지적선택，PE적문제급소득적쌍중래원지문제등。
As a new-rising financing measure, asset securitization has soon become fashionable globally in a short period of 20 years owing to its particular characteristics and superiority. China has also made a stride in the pilot securitization of credit assets. However, asset securitization is not an isolated process, which requires a set of systems, including law, accounting and tax systems etc. which suit it well. The tax factor holds the balance in the process of Asset Securitization and directly affects its efficiency of financing. Tax matters in the transnational asset securitization are especially of its own feature. The transactional method of transnational asset securitization is first looked through in this paper, and then the concerning international double taxation issues are discussed, including the choice of location of SPV, Permanent Establishment and double source income, etc. Because it is the first time to discuss this issue in China, the author hopes that this article could lead to more thoughtful discussions.