美国州际公司所得税协调机制及对我国的启示——以MTC为例

新的企业所得税法关于汇总纳税的规定使我国面临着大规模的地方政府间所得税分配问题。然而这一问题并非我国所独有。美国跨州税收委员会(MTC)是美国州际公司所得税协调机制的重要组成部分,考察MTC的成立背景和近40年的协调实践活动,有助于加深对我国企业所得税分配问题的理解,并得出有益的启示。     

关于我国地方税主体税种选择的思考

地方税主体税种的选择是构建地方税体系的重点内容之一，目前大多数有关地方税的文章都对这一问题进行了探讨，而且都提出了自己的看法，但大都较笼统。本文作者详细分析了影响地方税主体税种选择的因素，探究了我国缺少主体税种的原因及其造成的危害，进而提出要根据税制改革的实际进度，分阶段、分地区地确定相应时期的主体税种。     

The Stability of Tax Elasticities over the Business Cycle in European Countries

We estimate short‐ and long‐run tax elasticities that capture the relationship between changes in national income and tax revenue. We show that the short‐run tax elasticity changes according to the business cycle. We estimate a two‐state Markov‐switching regression on a novel data set of tax policy reforms in 15 European countries from 1980 to 2013, showing that the elasticities during booms and recessions are statistically (and often economically) different. The elasticities of personal income taxes, corporate income taxes, indirect taxes and social contributions tend to be larger during recessions. Estimates of long‐run elasticities are in line with existing literature.     

Company Tax Reform in the European Union

The European Commission recently proposed to move towards a consolidated tax base for European multinational companies, to be allocated across EU member states through a system of formula apportionment. This paper argues that while the Commission's blueprints for company tax reform may reduce existing problems of transfer pricing, they will also create new distortions as long as existing tax rate differentials are maintained. The paper also investigates the changes in international tax spillovers which will occur as a result of a switch from the current system of separate accounting to formula apportionment. The final part of the paper discusses whether more conventional corporate tax harmonization should still be a long term policy goal for the EU and presents quantitative estimates of the efficiency gains from harmonization.     

How Much Tax Coordination in the European Union?

This paper examines the trade-offs between tax autonomy and fiscal neutrality that the Member States of the European Union face in coordinating their taxes on consumption, labor and capital. One of the main messages is that in many cases tax reform should precede tax harmonization, mainly because the costs of distortions within Member States may be greater than the gains from reducing intergovernmental tax competition.     

Electronic Commerce and the State Retail Sales Tax: A Challenge to American Federalism

Electronic commerce, by magnifying problems with the existing sales tax, has precipitated reexamination of basic precepts of fiscal federalism in the United States, not just taxation of remote sellers. This paper examines: key features of electronic commerce; the Internet Tax Freedom Act and the Commission it mandates; tax assignments in the United States; problems in assigning sales taxes to subnational governments; constitutional impediments to requiring remote vendors to collect sales and use taxes; tentative findings of the National Tax Association's project on taxation of electronic commerce; and implications of the current debate over taxation of electronic commerce for intergovernmental fiscal relations in the United States.     

Attitudes towards Tax Levels: A Multi‐Tax Comparison*

We analyse Swedes' opinions about the levels of 11 different taxes to see which taxes people are most averse to and why. The most unpopular tax is the real estate tax, while the corporate tax is the least unpopular. We find a strong self‐interest effect in tax attitudes and that knowledge and education increase support for corrective taxes.     

完善结构性减税政策的着力点与路径选择

根据目前我国所面临的新形势、新任务,完善结构性减税政策的着力点应该放在三个方面:针对特定税种进行有增有减的调整,促进税制结构的优化;针对特定群体实行减税或增税政策,实现税收负担的公平;将结构性减税与经济结构调整对接,助推经济结构的优化。立足于这三大着力点,完善结构性减税政策的基本路径选择为:推进增值税扩围改革;调整消费税;减免部分进口环节税收;实行综合与分类相结合的个人所得税制;进一步完善企业所得税优惠政策;深化个人住房房产税改革;全面推广资源税;研究开征环境保护税等新税种。     

Corporate tax policy and incorporation in the EU

In Europe, declining corporate tax rates have come along with rising tax-to-GDP ratios. This paper explores to what extent income shifting from the personal to the corporate tax base can explain these diverging developments. We exploit a panel of European data on legal form of business to analyze income shifting via incorporation. The results suggest that the effect is significant and large. It implies that the revenue effects of lower corporate tax rates—possibly induced by tax competition—will partly show up in lower personal tax revenues rather than lower corporate tax revenues. Simulations suggest that between 12% and 21% of corporate tax revenue can be attributed to income shifting. Income shifting is found to have raised the corporate tax-to-GDP ratio by some 0.25% points since the early 1990s. This research was carried out while Ruud de Mooij was a visiting fellow at DG ECFIN in October 2006. The views expressed in this Article are those of the authors and do not necessarily reflect the official position of the European Commission.     

Coordinating VATs Between EU Member States

The paper surveys coordination requirements for a final European VAT (short for viable integrated VAT) system. Using a set of criteria that can be identified from the EU VAT program for the single market, we analyze the potential superiority of the Commission's 1996 VAT proposal and four alternative VAT systems over the current transitional regime. We argue that the recent withdrawal of the 1996 VAT proposal is economically beneficial, as this VAT reform would have generated substantial costs for EU member states due to losses in national tax autonomy and adverse incentives in VAT collection and control. If the Commission adheres to its political desiderata, the VIVAT regime turns out to be a promising blueprint for the EU. If the Commission decides to lay aside its preference for compliance symmetry, and accepts that different treatment of domestic and cross-border supplies under the transitional VAT regime should not be regarded discriminatory in the Internal Market, then keeping and revising the transitional system should turn out to be a good VAT strategy for Europe.     

On the Costs of Excise Taxes and Income Taxes in the UK

This paper develops an analytical framework for estimating the marginal excess burden (MEB) of taxes on gasoline, alcohol, tobacco, and labor in the UK, accounting for externalities and interactions among the taxes. Under most scenarios the MEB of the gasoline tax exceeds that for the labor tax, the MEB of the alcohol tax is roughly the same, while the MEB of the tobacco tax is lower than for the labor tax. These preliminary findings suggest that the gasoline tax may be too high, the alcohol tax might be about right, and the tobacco tax might be too low.     

Taxes

This is a compendium of notes on taxes. Section 2 presents a general tax scheme. It is a tax on value added by labour and capital that does not favour one or the other. Section 3 contrasts taxation of business income for pass-through entities and corporations. Section 4 discusses property taxes as taxes on housing services and so a form of income tax. Section 5 turns to wealth taxes. The closing Section 6 attempts to explain why people donate to nonprofits but minimise tax payments to governments, even though governments and nonprofits engage in many of the same activities.     

加强离岸股权转让税收管理

离案股权转让涉及税种较多,本文从离岸股权转让涉及的有关税种出发,逐一剖析了离岸股权转让过程中的税收问题,并从税收政策和征管两个方面对加强离案股权转让税收管理提出了建议。     

发达国家不同能耗模式及节能税收政策研究

发达国家在其经济发展史上呈现出两种截然不同的能耗模式:一是以美国为代表的高能耗模式;二是以欧洲和日本为代表的低能耗模式,不同能耗模式的形成与这些国家的税收政策密切相关。我国建设资源节约型社会,应借鉴发达国家的先进经验,适当调整现行税制,开征部分新税种,构建一套科学、完整的资源节约型税收体系。     

Personal Taxation in Firm Market Valuation: Theory and Test*

In this paper, I extend Ohlson's 1995 firm market valuation model to incorporate personal taxes: the taxes on dividends and the taxes on capital gains. Without personal taxes, firm market value can be expressed as the present value of future benefits received by the shareholders (dividends, in this case). With personal taxes, the benefits received by the shareholders should be classified into three categories (due to their different tax treatments): dividends, share repurchases, and new share issues (i.e., contributed capital). The extended model shows the effects of personal taxation on firm market valuation: retained earnings are valued less than contributed stocks, both dividends taxes and capital gains taxes affect retained earnings valuation and firm market value, and firms choose cash distribution methods (paying dividends and repurchasing shares) to increase their retained earnings valuation, therefore increasing their market value. An empirical test using a sample from the Disclosure Select Canada and Financial Post Card data bases for the years 1995‐98 supports these personal tax effects.     

Environmental taxation and the double dividend: A reader's guide

There has been considerable debate as to whether the revenue-neutral substitution of environmental taxes for ordinary income taxes might offer a double dividend: not only (1) improve the environment but also (2) reduce certain costs of the tax system. This paper articulates different notions of double dividend and examines the theoretical and empirical evidence for each. It also connects the double-dividend issue with principles of optimal environmental taxation in a second-best setting.A weak double-dividend claim-that returning tax revenues through cuts in distortionary taxes leads to cost savings relative to the case where revenues are returned lump sum-is easily defended on theoretical grounds and (thankfully) receives wide support from numerical simulations. The stronger versions contend that revenueneutral swaps of environmental taxes for ordinary distortionary taxes involve zero or negative gross costs. Theoretical analyses and numerical results tend to cast doubt on the strong double-dividend claim, although the theoretical case is not air-tight and the numerical evidence is mixed.     

International interest withholding taxation: Prospects for a common European policy

In 1989 the European Union member states rejected a proposal to introduce a minimum interest withholding tax of 15 percent. Some Union member states, however, remain keenly interested in bringing about some minimum level of international taxation of interest income. This suggests that member states will be asked to reconsider the issue in the near future. This paper first examines the effects of interest withholding taxes on financial markets. It then reviews some of the main aspects of potential tax reform in this area. A major challenge for any future proposal will be to satisfactorily integrate the banking system into a common interest withholding scheme.     

Incentives and Information Exchange in International Taxation

The exchange of taxpayer-specific information between national tax authorities has recently emerged as a key and controversial topic in international tax policy discussions, most notably with the OECD's harmful tax practices project and the EU's savings tax initiative. This paper analyzes the effects of information exchange and withholding taxes, recognizing that countries which agree to exchange information do not forfeit the ability to levy withholding taxes, and also focusing in particular on the effects of innovative revenue-sharing arrangements. Amongst the findings are that: (i) the transfer of withholding tax receipts to the residence country, as planned in the European Union, has no effect on equilibrium tax rates, but acts purely as a lump-sum transfer; (ii) in contrast, allocating some of the revenue from information exchange to the source country—counter to usual practice (though no less so than the EU agreement)—would have adverse strategic effects on total revenue; (iii) nevertheless, any withholding tax regime is Pareto dominated by information exchange combined with appropriate revenue sharing; and, in particular, (iv) sharing of the additional revenues raised from information provided, while efficiency-reducing, could be in the interests of large countries as a means of persuading small countries to provide that information voluntarily. JEL Code: H77, H87, F42     

The European Commission's Report on Company Income Taxation: What the EU Can Learn from the Experience of the US States

The European Union Commission has proposed using consolidated base taxation and formulary apportionment to tax the EU-source income of multinational companies. This paper examines US state experience with a similar approach. Despite some positive lessons, especially the need to consolidate income of affiliated companies, lessons are mostly negative, especially regarding the choice of apportionment formula, the use of economic criteria to define the group whose income is to be consolidated, and complexity caused by lack of uniformity. US experience says nothing about using value added to apportion income—an approach that is conceptually attractive, but subject to transfer pricing problems.     

财产税改革的逻辑

财产税与地方财政有着紧密的联系,多数划归为地方税。从财产税的性质来看,也适宜做地方税。这表明财产税的功能设计只能是以筹集收入为主,调节为辅。由此,财产税改革就应注重从宽税基、简税制和易征管,以及结合我国地方财政体制改革的要求来设计。我国财产税改革:一是替代原来已经不合时宜的相关税种;二是替代基层政府不具有地方税属性的税种。这两个”替代”若能实现,便可以”一箭双雕”,既能完善税制,又能理顺政府间财政关系。