回顾美国制定CFC规则的背景及其多年来的争论,有助于理解选择建立该规则的时机。我国现阶段暂不宜实施CFC规则。理由是: CFC规则会降低企业的国际竞争力,与我国鼓励企业“走出去”的宏观政策相悖,对“走出去”企业不公平,并且CFC规则的效果非常有限。 Reviewing the background of the United States in formulating the CFC rules and their years of controversy helped to understand the timing of the election to establish the rules. It is not appropriate for China to implement CFC rules at this stage. The reason is that CFC rules will reduce the international competitiveness of enterprises, contrary to the macro-policy of encouraging enterprises to “go global” in our country, unfair to “going global” enterprises, and the effect of CFC rules is very limited.