粤港澳大湾区建设中的税制差异研究

粤港澳大湾区要实现经济一体化,必然要克服香港、澳门和广东三地之间的税制差异带来的冲突问题。香港和澳门在"一国两制"的基础下被赋予税收立法权,税制协调的基础是保障香港和澳门的税收独立。粤港澳三地之间的税制差异主要表现在税率、税种、税收特点、税收管辖、税收征管等方面,正是这些差异使得在大湾区建设中产生重复征税、逃税避税、税收利益分配不均衡以及征管机构行政管辖权冲突等问题,从而阻碍粤港澳三地的经济发展。

Study on the Tax System Differences in the Construction of the Guangdong-Hong Kong-Macao Greater Bay Area

To achieve economic integration in the Guangdong-Hong Kong-Macao Greater Bay Area, it is inevitable to overcome the conflicts caused by the differences in tax systems between Hong Kong, Macao and Guangdong. Hong Kong and Macao are endowed with taxation legislative power on the basis of"one country, two systems", and the basis for tax coordination is to guarantee the independence of taxation of Hong Kong and Macao.The differences in tax systems between Guangdong, Hong Kong and Macao are mainly reflected in tax rates, tax types, tax characteristics, tax jurisdiction, tax collection and management, etc. It is these differences that have led to double taxation, tax evasion and tax benefit distribution in the construction of the Greater Bay Area Problems such as imbalances and conflicts in the administrative jurisdiction of the collection agencies hindered the economic development of Guangdong, Hong Kong and Macao.