关键词：
International
Tax avoidance
Capital gains
Offshore investing
Fiscal policy
Compliance
摘要：
Numerous countries (e.g.. Canada, Australia, and Japan) tax foreigners on the gains realized on transfers of interests in foreign entities that invest directly or indirectly in real estate in those countries. In the last few years, actions taken by tax authorities in India, China, Brazil, Indonesia, and other non-Organization for Economic Co-operation and Development countries have highlighted the possibility of taxing a broader range of indirect share transfers by foreigners. This article argues that taxing indirect transfers can have vital policy significance in countries where foreign inbound investments are actively traded in offshore markets: it not only deters tax avoidance, but may also stanch legal base erosion -- the substitution of offshore investment structures for legal mechanisms in onshore markets. The successful implementation of a broad policy of taxing indirect transfers, however, depends crucially on securing voluntary taxpayer compliance.
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