减税降费的价格和福利效应——引入成本传导率的投入产出价格模型分析

本文在增值税抵扣机制的投入产出价格模型中引入社保费和成本传导机制,并利用2017年中国投入产出表和税收数据模拟分析了不同成本传导率条件下,减税降费的价格效应和福利效应。研究表明:(1)减税降费使得各行业产品价格降低,对第三产业的价格影响最为明显。(2)成本传导率越高,则产品价格的下降幅度越大。当成本传导率分别为1/3、2/3和1时,各行业产品价格的平均下降幅度分别为0.32%、0.93%和2.66%。(3)较为合理的中国整体成本传导率约为1/3,减税降费是2019年中国PPI下降的主要因素之一。当成本传导率为1/3时,模拟计算的PPI下降幅度与国家统计局公布的2019年PPI的下降幅度(-0.3%)非常接近。(4)减税降费使消费者价格下降,居民福利得以改善,且城镇居民福利改善高于农村居民。随着价格传导率增大,城镇居民与农村居民的人均福利改善差距扩大。     

国外税务稽查经验及借鉴

当今,世界各国税务机关普遍重视稽查工作,一方面将财力、物力和人力向稽查部门倾斜,并借助科技力量和法律武器为税务稽查保驾护航;另一方面,加强税务稽查案源信息管理,以提高稽查工作的质量和效率。本文借鉴国外先进经验,提出了未来我国税务稽查应当在组织、流程以及法律保障等方面进行改进,以减少税收流失,提高全民纳税意识。     

Transfer Pricing, Incentive Compensation and Tax Avoidance in a Multi-Division Firm

This article examines the relation between transfer pricing and production incentives using a model of a vertically integrated firm with divisions located in different tax jurisdictions. We show that if divisional profits are taxed at the same marginal rate, the transfer price should be set to minimize the compensation risk faced by the manager of the buying division. For the case where divisional profits are taxed at different marginal rates, we are able to characterize the trade-off between the tax savings from setting transfer prices to reduce profitability in the high tax jurisdication and the loss of effort attributable to the impact of tax avoidance on the incentive compensation system. Further, we show that if it is feasible to compensate the division managers using multiple performance measures, the transfer price should be used to minimize the firm's overall tax liability. Finally, we show that when authority to determine the transfer price must be delegated to one of the division managers, it is optimal to assign responsibility for setting the transfer price to the manager of the division with the most production uncertainty.     

论税收之债的自力执行

税收之债具有自力执行的效力。所谓税收之债的自力执行,是指税务机关行使征税职权,遇有纳税人拒不履行按期足额纳税义务时,税务机关可以直接采取强制措施迫使纳税人履行纳税义务。各国税法之所以赋予税收之债自力执行的效力,主要是基于行政效力先定、税收确实及效率原则以及税收的公益性等因素的考量。同时,为了有效防止或监督税务机关滥施行政强制现象的发生,我国税法对税务机关自力执行权的行使范围、条件和程序予以了严格限制。     

Tax Competition and Foreign Capital

This paper derives welfare equivalence of double taxation rules in a tax competition model with discriminatory home taxes and the ability to finance subsidiary operations with host country capital. For a more general model, we provide sufficient conditions on the number of host sectors and factors that support double-tax-rule equivalence. Examples violating these conditions help identify economic factors under which a home country has strict preferences over double taxation rules. If the home tax rate can influence host factor prices, the home country weakly prefers deductions over credits as in the pure-home-equity financing case.     

A collateral tax sanction: When does it mimic a welfare-improving tag?

The suspension of a driver’s license or the revocation of a passport or a professional license are used by the tax authorities as sanctions for failure to comply with tax obligations and are referred to as collateral tax sanctions. In this paper, I propose a new rationale for why it may be beneficial to use collateral tax sanctions for the purpose of tax enforcement. By affecting consumption and providing enforcement targeted to a group, collateral tax sanctions may allow the government to impose punishment correlated with an individual’s earning potential. Such punishment also makes the effective tax rates correlated with an individuals’ earning potential and therefore leads to a more effective redistribution of income. I show that the use of collateral tax sanctions could increase the CES social welfare function when the skill distribution of the targeted group first-order stochastically dominates the skill distribution of the other group and the social welfare function is sufficiently concave.     

Tax competition, excludable public goods, and user charges

This paper provides an explanation for the increasing reliance on revenue from user charges on excludable public goods. We develop a model with many identical countries. The government of each country imposes a source-based tax on capital and supplies an excludable public good to heterogeneous households. Without tax competition, the price on the public good is zero. Tax competition induces each country to choose a positive price. The reliance on user charges turns out to be increasing in the intensity of tax competition measured by the number of countries. A coordinated decrease in user charges is shown to raise welfare in all countries.      

Standards across borders: crossborder diffusion of the arm's length standard in North America

The arm's length standard is used by corporate income tax authorities to price international intracorporate transactions and allocate intracorporate income and expenses of multinational enterprises. In this paper, we examine the socio-historical evolution of transfer pricing regulation in North America. We develop a model of crossborder diffusion of standards, using institutional theory and the logic of embeddedness, that focuses on three components of crossborder diffusion: timing, motivation and form. Our model is then applied to the evolution and diffusion of the arm's length standard within North America from 1917 to the present.     

Price Stability in Economies with Habit Persistence

This paper shows that the divine‐coincidence does not hold in a sticky price model with external habit if a time‐varying tax rate on labor income is not implemented to fully eliminate the time‐varying distortions associated with external habit and monopoly power in goods market. The required labor income tax rate is inversely related to the risk‐free real interest rate and the markup in the goods market, but it is proportional to the degree of external habit. Under this circumstance, the optimal monetary policy commands a countercyclical interest rate, having a perfect negative correlation with tax rate in the sticky price model with external habit. If a time‐invariant tax is the only fiscal instrument, then the degree of external habit entails a gap between the private marginal rate of substitution between consumption and labor and the social marginal rate of substitution, generating an endogenous trade‐off between the stabilization of welfare‐relevant output gap and inflation. Under this circumstance, price stability is not the optimal policy. The monetary policy authority should optimally try to undo the time‐varying distortions associated with external habit and monopoly power in goods market by deviating from price stability.     

Food prices,tax reforms and consumer Welfare in Tanzania 1991–2007

This paper analyses the effect of observed food price changes on household consumption (welfare) in Tanzania and from this simulates the welfare effect attributable to tax (tariffs and VAT) reforms. The three rounds of the Tanzania Household Budget Survey (1991/92, 2000/01 and 2007) are used to apply Deaton’s method based on median unit values (prices) and household budget shares. The results indicate that real price increases over 1991–2007 have reduced welfare of the average household by 20 per cent of 1991 income, and the loss was fairly evenly distributed between the 1990s and 2000s. The welfare loss was much greater for the poor, especially the rural poor (a 27 per cent reduction), compared to the non-poor (in particular the urban non-poor, who suffered a five per cent loss). Although we cannot establish explicit links between tax reforms and domestic commodity price changes, to assess the extent to which welfare changes can be explained by tax reforms we simulate the effects of tax changes on domestic price changes. The simulation shows that tax reforms (tariff reductions) offset the welfare losses for all household groups, especially in the 1990s; although the differences were small, the urban poor benefit more in relative terms from tax reforms whereas the rural poor benefit least (the effect on the non-poor was similar irrespective of location).     

Optimal taxation with home production

Optimal taxes for Europe and the U.S. are derived in a realistically calibrated model in which agents buy consumption goods and services and use home capital and labor to produce household services. The optimal tax rate on services is substantially lower than the tax rate on goods. Specifically, the planner cannot tax home production directly and instead lowers the tax rate on market services to increase the relative price of home production. The optimal tax rate on the return to home capital is strictly positive and the welfare gains from switching to optimal taxes are large.     

对个人住房开征物业税的几个判断及效应预测

对个人住房开征物业税是关乎国计民生的大事。本文认为,开征物业税之前需要进一步理顺中央与地方的财政关系;开征后的物业税收入要用于满足地方公共财政支出的需要;物业税开征后的征管质量取决于对个人住房信息的掌握和政府各部门间的横向合作。物业税开征与地区房地产价格弱相关,与全国房地产价格无关;与股市题材炒作相关,与资本市场发育无关;与当地居民收入和福利相关,与辖区外居民效用无关。     

浅议涉外税务审计工作

涉外税务审计是税务机关的一项重要税收管理工作。本文阐述了审计人员在审计过程中必须正确处理目的与手段、管理与服务、效率与程序之间的关系。同时建议应从提高对涉外税务审计工作的认知度,提高税务审计人员的专业素质,提高税务审计的信息化水平和完善涉外税务审计制度四个方面来完善我国涉外税务审计工作。     

Do auditors constrain intertemporal income shifting in private companies?*

This study investigates the association between private company auditing and intertemporal income shifting. Using a large reduction in the Finnish corporate tax rate as a strong incentive for income shifting and financial statement data coupled with proprietary information from the tax authorities, we analyse accruals and cost stickiness of small private companies. Our results reveal significant differences in accrual income shifting between audited and unaudited companies, but only among companies that on average could anticipate the tax reduction the most. Further, we find auditors to restrict sticky selling, general, and administrative cost behaviour that we hypothesise is associated with illegal actions. Additional tests expose a nontrivial number of incorrectly unaudited companies which are the ones mostly associated with income shifting. Taken together, our study highlights the effects of audit exemption and the importance of enforcement while also suggesting that the audit process is value adding for the tax authorities.     

Transfer pricing in vertically integrated industries

Tax officials judge whether a multinational’s transfer price is consistent with the arm’s-length standard, the price at which two independent firms would carry out a similar transaction, by using data from comparable but independent transactions. In vertically integrated industries, the only source of comparable data may be from controlled (nonindependent) transactions. Conventional wisdom asserts that standard arm’s-length methods cannot perform well in such markets because the comparability rules encourage the integrated firms to collude tacitly on transfer prices in a way that amplifies tax-differential incentives. In this paper, we show that strategic linkages between vertically integrated firms operating in the same final good market moderate, and can possibly reverse, tax-differential incentives if the correct comparison method is used. The Cost-Plus method turns out to be the most effective in limiting the equilibrium amount of profit-shifting out of the high-tax country and it yields the highest tax revenues for the high-tax country. These benefits are shown to strengthen when the firms have private cost information.      

Earnings,institutional investors,tax avoidance,and firm value: Evidence from Taiwan

This study examines the valuation of earnings from China and Taiwan by foreign and domestic institutional investors across a sample of Taiwanese electronics firms. We further compare the valuation of firm earnings reported in tax havens and non-tax havens, and whether these firms have changed tax avoidance activities since 2004 when the Taiwanese government enacted stricter auditing of transfer pricing regulation.Our findings show that both operating income from the home country and investment income are positively associated with firm value. Operating income from China, however, is not significantly related to firm value when institutional ownership of the firm exceeds fifty percent. This result indicates that operating income is valued differently, depending on the location from which the income was generated. Non-operating income enhances firm value regardless of the revenue source. We also report that foreign institutional investors favor operating income from domestic and investment sources over earnings generated from non-domestic sources and other non-operating income. Furthermore, our results suggest that firms rearrange reported profits from subsidiaries located in tax havens to affiliates in other countries following the transfer pricing audit guide Taiwan implemented in 2004. Results also indicate firms may have been shifting profits to other low-tax-rate countries, or to countries which do not require firms to pay taxes, even if they are not doing business in that country.     

现行主要税种税收超额负担分析

税收超额负担是超过政府所征集的税收收入而形成的社会净福利损失。税收超额负担是税收效率分析的核心，它可以借助于消费者和生产者剩余以及无差异曲线进行分析，分析过程应更关注征税引起的价格变动的替代效应，我国现行主体税种都不同程度地破坏了各种市场资源配置的均衡条件，降低了经济运行效率，产生了超额负担。通过对税收超额负担的分析能够得出有助于提高资源配置效率的各种结论。     

论对个人财产转移信托的课税

随着信托业务的不断发展,以财产保护和转移为目标的财产转移信托在我国已经出现。财产转移信托具有特殊的财产权架构,因而导致其税收法律关系出现较为复杂的变化。由于我国尚未建立财产转移信托税收制度,信托税收法律关系的变化将产生不利于社会公平、不利于防范避税等一系列负面问题。本文认为,我国应当按照信托受益人课税和信托主体课税的原则构建相关信托税收制度。     

International tax competition with endogenous sequencing

This paper examines endogenous timing in an international tax competition model. Unlike existing studies, governments are assumed to decide not only tax rates but also whether they are set early or late. The Nash equilibrium provides four conclusions for alternative double tax allowances. First, tax deductions cause simultaneous tax competition, whereas tax credits yield sequential tax competition. Second, any double taxation relief would generate capital trade. Third, a credit system could maximize one country’s economic welfare but would lower another country’s economic welfare more than a deduction regime. Fourth, a home country’s government would choose credit regimes under a maximax rule, but select deduction methods under minimax and maximin rules, while all double tax allowances are indifferent to a host country. The findings resolve the question raised by Bond and Samuelson (Economic Journal 99:1099–1111, 1989) of why governments choose tax credits when tax deductions are clearly better. Namely, this paper shows that one country is better off but another is worse off with credits rather than deductions. Accordingly, we cannot clearly specify whether governments choose credit systems or deduction regimes. The possible double tax allowances employed by the governments depend on their own decision criterion.     

Tax Havens,Tax Evasion and Tax Information Exchange Agreements in the OECD

Using data on Foreign Portfolio Investment (FPI), we find a positive relationship between higher tax burden and OECD residents’ tax evasion, especially via tax havens. Contrary to established investor preference for certain country characteristics, we find they are less important to tax evaders who value privacy and want to remain undetected by their home tax authorities. We find very limited evidence that OECD Tax Information Exchange Agreements (TIEAS) reduce tax evasion, controlling for other determinants of overall OECD FPI. Without the US in the OECD sample, tax havens play a lesser role and OECD policies appear to make a marginal impact.