对符合权益持续性的企业重组给予免税待遇是世界各国通行的税收惯例,但模糊不清的免税规则易导致巨大的税收筹划空间,形成无谓的经济效率损失。美国免税资产与产权重组规则完备并极具典型性,为我国设立细节化、明确化的免税规则与反滥用措施提供了参考。 Tax-exempt treatment of corporate restructuring in line with the continuity of rights and interests is a common tax practice in various countries in the world. However, ambiguous tax-exempt rules can easily lead to huge tax planning space and create unnecessary loss of economic efficiency. The tax-free assets and property rights restructuring rules in the United States are complete and very typical, providing a reference for our country to set up detailed and explicit tax-exempt rules and anti-abuse measures.