所得税会计准则的国际比较

企业所得税是发达国家的主体税种,也是我国的重要税种。所得税会计作为现代税务会计的核心颇受各国重视。为了规范所得税的会计确认、计量与披露,国际上许多国家制定了所得税会计准则或会计制度。本文通过英国、美国、中国的所得税会计准则与国际会计准则的比较,揭示其相互之间的共性与主要差异,并对进一步完善我国的所得税会计准则提出相应建议。     

Implications of the US Tax Reform for Transatlantic FDI

On 22 December 2017 President Trump signed the Tax Cuts and Jobs Act. This corporate tax reform can be considered the most significant amendment of the US corporate tax code since 1986. Besides the reduction of the corporate income tax rate from 35% to 21%, the Tax Cuts and Jobs Act entails features like a switch from worldwide income taxation to territorial taxation, as well as immediate deductions for certain assets. This leads to a substantial improvement for the US in global tax competition. In this paper, we analyse the effects of the US tax reform on FDI flows between Europe and the US. We find that European high-tax countries in particular will suffer from a net outflow of FDI.     

企业所得税税负归宿与收入分配

企业所得税对收入分配具有重要影响,本文将企业所得税税负归宿问题内生化来研究其对收入分配的影响,使用2010年的数据研究企业所得税的税负归宿发现,相对于国家实际征得的企业所得税,资本要素承担了超过100%的税收负担,而劳动要素在我国企业所得税的税负归宿中受益;在收入分配方面,企业所得税具有一定的累进性,能够减少城乡之间、城乡不同收入群体之间的收入分配差距.本文的研究表明,企业所得税对不同收入群体收入的影响大体呈倒U字型分布,因此,降低企业所得税虽然可能导致收入分配进一步恶化,但有利于提高最低收入阶层收入占国民总收入的比重;提高企业所得税虽然有利于调节收入分配,但应注意配合其他措施提高低收入者收入.     

The Effect of State Corporate Income Tax Rate Cuts on Job Creation

This paper compares the employment growth of states that enacted corporate income tax rate cuts in the past 23 years with those making no changes. Overall employment comparisons from 1990 to 2012 suggest that a reduction in the corporate income tax rate is associated with faster job creation. The states that cut corporate income tax rates started with slower employment growth than the states that made no changes. However, the growth gaps between the two groups of states disappeared in about five years after the tax cuts were made. Regression results confirm the observation that lower corporate tax rates have a significant and positive effect on employment growth. The enactment of a tax rate cut also has the additional but temporary benefit of promoting job creation as businesses adjust to the new tax rate. However, this benefit is temporary and only occurs during first year of the enactment of a tax cut.     

外资企业税收负担与FDI规模——基于省级面板数据的分析

本文将外资企业的增值税和企业所得税税负作为主要的解释变量，利用省级面板数据来实证检验其对地区FDI规模的影响，并通过测算相关系数来分析FDI对增值税和企业所得税税负的敏感程度，分析表明：不论是增值税税负还是企业所得税税负，都对地区的FDI规模有较强的负面影响，相比于增值税税负，FDI对企业所得税税负的敏感程度更高。     

The economic consequences of corporate tax rates reductions in the EU: Evidence using a computable general equilibrium model

In a globalised world, governments are eager to attract foreign investors by lowering corporate tax rates. Recent trends point towards a revival of a race to the bottom in corporate income tax (CIT) rates in developed economies. EU countries have been active in this respect. A generalised fall in CIT rate could prove detrimental to tax revenues and trigger increase in other taxes to meet fiscal policy objectives. However, it could also spur investment and growth and prove to be a good fiscal policy strategy if, as a result, the corporate tax base increases. The final economic and fiscal impact of a reduction in CIT rates is therefore unclear. Using a CGE model, we find that uncoordinated tax reforms significantly impact national economies and third‐country effects can be significant when large countries implement CIT rate cuts. Small countries are better off unilaterally reducing their CIT rate at the expense of other EU countries. We find that negative spillovers are mitigated when the country reducing its CIT rate restores its budget balance by cutting either public expenditures or social transfers. A larger degree of non‐EU capital mobility also tends to reduce the negative spillover effects of unilateral CIT rate reductions.     

Does Trade Liberalisation Trigger Tax Competition? Theory and Evidence from OECD Countries

This paper aims at assessing the empirical relevance of new economic geography models of tax competition. We rely on a simple model to specify tax reactions functions, which we estimate with a panel covering (up to) 26 OECD countries over the period 1982 to 2006. We provide striking support for the two main predictions regarding the slope and the constant of the reaction function: national governments seem to adjust their corporate tax rate towards the level chosen in countries that are more populated, and they tend to set higher corporate tax rates when their country enjoys a high real market potential. Through the latter effect, trade integration exerts a positive influence on the level of corporate taxation. However, using a theoretically grounded index of bilateral trade integration, we also show that trade liberalisation gives rise to significant tax interactions in the setting of effective average tax rates in the case of European countries, thus exerting a downward pressure on corporate tax rates.     

Do taxes influence the organizational boundaries of international firms? An incomplete-contracting model with empirical evidence

Firms that import intermediate goods choose between outsourcing and vertical integration. When corporate tax rates differ between the home country and the foreign country, the possibility of shifting income and reducing overall tax payments through transfer pricing makes integration more attractive than outsourcing. This paper develops an incomplete-contracting model in which an international firm facing tax rate differentials chooses whether or not to internalize intermediate transactions in order to trade off production efficiency and tax minimization. By shifting economic activities across borders, an integrated multinational enterprise establishes a proper transfer price and reaches the optimal profit-splitting arrangement that maximizes its total after-tax profit. This paper finds that cross-country differences in corporate tax rates and product intangibility play important roles in affecting firms’ internalization decision. Empirical analysis employing the US data also supports the theoretical findings. The positive correlation of the integration level of US firms and tax rate differentials between the US and foreign countries remains in the sample excluding tax havens.     

Cross-border pollution,public pollution abatement and capital tax competition

We analyze the case where governments have to use income tax revenue to finance public pollution abatement and relate the results to the existing literature on capital tax competition. We show that the impact of public pollution abatement on Nash taxes on mobile factor income is non-trivial and the standard results from the tax competition literature can be reversed. When the two countries are identical, the Nash equilibrium capital income taxes converge to the tax on immobile factors income as the degree of cross-border pollution converges to one. When countries are asymmetric and pollution is local the presence of public pollution abatement lowers the capital tax for the capital exporting country, while the impact on the capital tax of the capital importing country is ambiguous.     

A minimum corporate tax rate would be harmful for both high and low tax countries

Conclusion  The corporate tax policy of the new EU member states does create pressures for some of the old member states to reduce their corporate taxes, in particular statutory corporate tax rates. But reacting to this pressure by enforcing mimimum tax rates in the EU would be counterproductive. It would slow down the economic catching up process in eastern Europe and question the competitiveness of the entire EU as a location for investment compared to other countries and regions in the world economy. There are potential benefits from more coordination in the field of corporate taxation, but this coordination should aim at removing tax obstacles to border-crossing investment and at reducing the compliance costs of the tax system. This requires targeted measures in the area of tax base coordination. Introducing minimum corporate tax rates, in contrast, would be harmful for both high and low tax countries in the EU.     

Abschaffung der Abgeltungsteuer — gerechter und steuersystematisch einheitlicher?

There is a rising political discussion in Germany around abolishing the final withholding tax on capital income. The German tax reforms that introduced this tax lowered tax rates, in particular on interest income. According to some authors, the growing inequality of income and property is a strong argument for the higher taxation of capital income. However, other authors argue that the neutrality aspects concerning private investment are inadequate. An abolishment of the final withholding tax would not solve these problems and, moreover, would turn back the achieved improvements. Therefore, the German Council of Economic Experts suggests complementing the previous reforms by introducing an allowance for corporate equity.     

浅析企业所得税费用的确认和计量

所得税会计关系着国家税款征收和企业收益分配。它主要是针对会计与税收处理规定的不同造成的资产、负债的账面价值与其计税基础的差异。如何确认相关的递延所得税,以及如何确定利润表中应予确认的所得税费用是本文论述的重点。     

Why do countries combine the exemption system for the taxation of foreign profits with domestic double taxation relief?

Many European countries exempt foreign profits from domestic corporate taxation. At the shareholder level, however, all corporate profits are taxed, and double taxation relief is granted only for domestic corporate taxes. This paper attempts to rationalize this tax policy. In the presence of double taxation agreements which exempt foreign profits from domestic corporate taxation, countries may use shareholder taxes to tax these profits. The disadvantage of shareholder taxes is that they create incentives to sell domestic firms to foreigners. But double taxation relief for domestic profits may preserve domestic ownership. Our results imply that national dividend tax policies may be a factor contributing to the empirically observed home bias in investment.     

宏观税负、税负结构和社会阶层分化的理论和实证分析

本文选取2005～2008年中国293个地级市各主体税种税负结构和城镇居民可支配收入数据,运用面板回归和截面回归等方法,实证分析了税负结构对居民可支配收入的影响和对不同收入阶层居民收入水平的影响。研究结果表明：（1）除个人所得税税收负担对居民可支配收入的影响较不显著外,增值税、营业税以及企业所得税税收负担对居民的可支配收入都有很显著的负向影响;（2）我国的税负结构并没有发挥应有的调节收入分配,减缓社会阶层分化的作用,并在一定程度上加剧了社会阶层的分化。本文的政策含义是：税负结构合理的关键是责权利的一致性或成本与受益的对称性,应当结合收入分配制度改革对税收制度进行相应调整,同时加强对非工薪收入的缴纳。     

Corporate tax systems, multinational enterprises, and economic integration

Multinational firms are known to shift profits and countries are known to compete over shifty profits. Two major principles for corporate taxation are Separate Accounting (SA) and Formula Apportionment (FA). These two principles have very different qualities when it comes to preventing profit shifting and preserving national tax autonomy. Most OECD countries use SA. In this paper we show that a reduction in trade barriers lowers equilibrium corporate taxes under SA, but leads to higher taxes under FA. From a welfare point of view, the choice of tax principle is shown to depend on the degree of economic integration.     

Endogenous cyclical corporate tax burden in China: The role of tax quotas and growth targets

Using data from China Annual Survey of Industrial Firms and addressing potential endogeneity problem, we find that corporate tax burden in China is procyclical during recessions and countercyclical during booms. The cyclicality is stronger for enterprises whose corporate income taxes are levied by Local Tax Bureau (LTB). Procyclicality of corporate tax burden during recessions is larger for enterprises located in county, non-state-owned enterprises (non-SOEs), non-high-tech enterprises and large-medium enterprises. Furthermore, tax quotas and growth targets of local governments enhance procyclicality during recessions and the countercyclicality of corporate tax burden during booms. Tax collection and government spending are important channels through which tax quotas and growth targets affect the cyclicality of corporate tax burden, respectively. This paper provides important policy implications for China during economic recessions.     

Can state tax policies be used to promote entrepreneurial activity?

Despite a recent flurry of empirical research on the effects of taxes on small business activity, state-level taxes faced by entrepreneurs have been overlooked by most of the existing literature. Using a 50-state panel of tax policy information spanning the years 1989 through 2002, our analysis reveals that state tax policies generally do not appear to have quantitatively important effects on entrepreneurial activity. When we find statistically important effects, we find that higher individual income tax rates, the existence of a state-level estate, inheritance or gift tax, and a higher weight on the sales factor in the state corporate income tax apportionment formula all slightly reduce a state’s share of the national entrepreneurial stock. Results also indicate that states with more progressive personal income tax structures and states that have more aggressive corporate income taxes through the imposition of a combined reporting requirement both tend to have slightly higher entrepreneurship rates. The composition of state tax portfolios is not found to be a significant determinant of state entrepreneurship.     

完善我国保险公司所得税税制研究

目前我国在保险公司所得税税制研究中,往往将注意力集中于所得税税负的统一、公正,降低小型保险公司税负等国家政策性税收扶持管理上。虽然在近些年来,我国税收制度在不断的深入发展,然而仍然与国际先进税收管理制度存在一定的差距。本文笔者就加强我国所得税税制研究做粗浅的探讨,并提出几个应该加强研究的所得税相关方面。     

税负水平上升对我国税收结构变动的影响

借鉴税收结构变动指数分析中国税负水平与税收结构整体波动的关系,并运用省际面板数据构建计量模型,进一步考察近十几年来税负水平的不断攀升对中国税收结构变动的影响。研究结果显示:税负水平的不断上升推动了税收结构的大幅调整,且使得税收增长更加依赖企业所得税;物价上涨和货币化水平对中国税收结构的变化产生了不同的影响。     

Valuation effects of recent corporate dividend and income trust distribution tax changes

We analyze the valuation effects of the Canadian federal government's announcement on November 23, 2005 of a reduction in the taxation of corporate dividends and the announcement on October 31, 2006 of a plan to eliminate the tax‐deductibility of income trust distributions. Though high dividend stocks and income trusts reacted positively to the 2005 announcement, the abnormal returns were greater for income trusts. Conversely, both securities reacted negatively to the 2006 announcement with the decline bigger for income trusts. The larger price reactions of income trusts and the lack of statistical significance in the cross‐sectional tests of the abnormal returns suggest that the popularity of income trusts in Canada was mostly driven by their favourable income tax status. The implications of these findings for scholarship and for practice are discussed. Copyright © 2008 ASAC. Published by John Wiley & Sons, Ltd.