China has preliminarily established a tax adjustment mechanism against the indirect equity transfer of non-resident enterprises, in the prevention and disposition of possible tax fraud or evades taxes. However, the incompletion of the tax jurisdiction, the ambiguity of identification standard and the institutional defects of tax collection and administration mode have become obstacles to realize the special tax adjustments intentions. Considering the anti-avoidance practice in China and the monolithic deployments of the further reform of the fiscal and taxation system, on condition that taxation-legalism should be insisted, rules and legislation should be improved and perfected to achieve the international tax coordination and justice.