八十年代中期,发源于英国继而以美国1986年大规模税制改革为先导,一场大规模税制改革浪潮席卷全球。当此起彼伏的改革浪涛逐渐平息下来后,发达国家和发展中国家的公司所得税税率结构和税率水平有了极大的改观。发达国家长期扮演高税率国角色的时代宣告结束,一些曾令世人瞩目的高税国,变成了税率温和的中税国甚至低税国。进入90年代中期,环顾今日世界,50%以上的公司所得税税率已是寥若晨星,达到40%以上的税率就可跻身于高税国之列。除了有避税地传统的那些国家和地区继续保持着低于25%以下的税率之外,大多数国家和地区所选择的税率水平介于30%-40%之间。税率水平的这种趋同之势,反映出各国经济之间的相互依赖与相互合作关系。身为资本和技术输出国的主要发达国家率先降低公司所得税税率,无形中给其他国家造成了压力。因为那些发达国家为消除国际双重征税而采用的外国税收限额抵免机制,将会使在高税率国家本国的投资者产生大量的得不到抵免的外国税负,这使高税率 The mid-eighties, originated in the United Kingdom and then the United States 1986 large-scale tax reform as the guide, a wave of large-scale tax reform swept the world. After the wave of reforms one after another gradually calmed down, the structure and rate of corporate income tax in developed and developing countries have greatly changed. The era in which the developed countries have long been playing the role of a high tax rate country has come to an end. Some high tax countries that have attracted worldwide attention have become moderate tax countries and even low tax countries. Into the mid-90s, looking around the world today, more than 50% of the corporate income tax rate is already rare, up to 40% of the tax rate can be among the high tax countries. Most countries and territories choose between 30% and 40% of the tax rates, except those tax havens who continue to hold tax rates below 25%. This trend of convergence in tax rates reflects the interdependence and mutual cooperation among the economies in various countries. As the major developed countries that are exporters of capital and technology are the first to lower their corporate income tax rates, they have virtually put pressure on other countries. Because the foreign tax quota credit mechanism adopted by developed countries to eliminate double taxation in the international community will generate a large number of foreign tax credits that can not be credited to domestic investors in countries with high tax rates,