| 英文摘要 |
The limited partnership, a new form of organization with corporate personality, is recognized as the profit-seeking enterprise under tax regulations. Therefore, it should apply to the tax credit system of integrated income tax. However, in practice, this system has caused many problems, including the complicated calculation of Imputation Credit Account and uneven tax burdens between domestic and foreign shareholders. Thus, this article, based on the pass through payment under US law or the Durchgriffstheorie under German law, proposed that we should attribute the profits and losses incurred in the operation directly to the partners. On the other hand, limited partnership may become an affiliated company with partner’s business; therefore, we should also take notice of the applications of non-arm’s-length transfer pricing and anti-thin capitalization.
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