國際間利用租稅庇護所進行控股及三角貿易行之有年，因此產生稅賦遞延與侵蝕。現因應國際反避稅，臺灣針對反避稅制定相關法規，規範租稅庇護所不再有稅賦遞延產生及稅盾效果，因此所得稅法第43條之3及所得稅法第43條之4訂定尚未實行，配合國際間稅務資訊交換的共同申報準則，維護租稅公平，減少稅基侵蝕。因此本研究針對臺灣上市櫃公司是是否有因為反避稅條款及將實行與共同申報準則的稅務資訊交換等措施，對海外投資逐漸減少，透過成對樣本T檢定分析，再以某上市公司為個案分析探討。T檢定結果得知臺灣企業對海外投資數額並無減少及亦無減少對稅務不合作地區之境外租稅庇護所家數。個案探討分析結果仍無減少對稅務不合作地區之境外租稅庇護所家數及投資金額。最後結論與建議仍可供臺灣企業參考之。;Use of tax shelters for holding and triangular trading between countries has been around for many years, which has resulted in tax deferral and erosion. Due to International Anti-Avoidance Rules, Taiwan has enacted relevant regulations on anti-avoidance Rules to regulate that tax shelters no longer have tax deferral and tax shield effects. Therefore, this research aims at whether Taiwan listed companies have gradually reduced overseas investment due to anti-avoidance provisions and tax information exchange with common reporting standards by paired T-test, then, chose a listed company to be as a case analysis and discussion. The results of paired T-test know that the amount of overseas investment by Taiwanese companies and the number of overseas tax shelters in areas that do not cooperate with taxation have not been decreased. The result of case study has still not reduced the number of overseas tax shelters and the amount of investment in areas that do not cooperate with taxation. The conclusions and suggestions can still be used for reference by Taiwanese companies.
