加拿大公司所得税制度与征管经验借鉴

加拿大的公司所得税制度体系完备,征管体系也较为合理,促进了经济的持续稳定发展。本文详细介绍了加拿大公司所得税制度及其征管体系,并提出我国在完善企业所得税制度时应借鉴其对公平与效率的兼顾以及加强税收征管的一些有效经验。     

公司所得税改革的世界趋势:价值取向与具体措施

随着经济全球化的发展和国际间资本流动的加速,在追求公平、效率、收入的基础上,世界公司所得税改革的价值取向已进一步提升到提高本国税制竞争力、吸引国际投资的高度,降低税率、扩大税基、消除股息双重征税以及对现金流量税的理论推崇也成为实现这一价值理念的基本措施。     

Meta-analysis categorization of EU countries in the context of corporate income tax

The corporate income tax is a corporate tax which aggregates economic, political and social aspects. The paper focuses on identification, analysis and assessment of homogenous EU countries groups, which show the common characteristics in the field of corporate taxation based on the selected segmentation criteria. Within the statistical meta-analysis in this paper some several methodical approaches were used: variants of agglomerative hierarchical cluster analysis, k-means method and fuzzy c-means and also multidimensional scaling method are implemented and compared. The purpose of this research is, in the context of theoretical implication to provide a synthesis of knowledge and empirical evidence about selected determinants of corporate taxation, and to verify the applicability of the clustering methods when gaining knowledge in the field of taxation. In the context of practical implication is the main purpose of this research the categorization of European countries into economically meaningful clusters, based on their similarity in corporate taxation, and to assess the convergence of European countries in corporate taxation. Results of provided cluster analysis are five groups of multidimensional objects with distinctive characteristics: nominal and effective corporate tax rate, economic performance and the level of debt.     

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.     

Prospects for Co-ordination of Corporate Taxation and the Taxation of Interest Income in the EU

This paper evaluates the recent proposals for a co-ordinated capital tax policy in the European Union, focusing on an EU-wide minimum withholding tax on interest income and alternative ways to increase the effective tax rate on corporate profits. The analysis draws on current theoretical and empirical research and views the recent capital tax reforms undertaken by individual member countries as rational adjustments to changing conditions in capital markets. Special emphasis is placed on the constraints for EU tax policy imposed by the possibility of shifting capital income to third countries. The paper concludes that some aggregate efficiency gains can be expected from the EU co-ordination proposals, but additional tax collections will be limited largely to the group of small savers while highly mobile large-scale investors are likely to avoid the EU tax.     

Corporate tax revenues in OECD countries

This paper studies variation among OECD countries in the size of corporate income tax revenues relative to GDP over the time period 1979–2002. A decomposition explains such variation as a function of the statutory tax rate, the breadth of the tax base, corporate profitability, and the share of the corporate sector in GDP. Empirical results indicate a parabolic relationship between tax rates and revenues, implying a revenue-maximizing corporate income tax rate of 33% for the whole sample. This revenue-maximizing rate is found to decrease as economies are smaller and more integrated with the world economy. JEL Classification H25, H87     

Debating Proposed Reforms of the Taxation of Corporate Income in the European Union

This paper reviews the European Commission's latest proposals (European Commission, 2002) for the co-ordination of corporation taxes within the EU. It provides a brief summary of the report, and then investigates the nature of the tax obstacles identified by the Commission, the conceptual basis of the location of taxation, and the relatively novel lack of attention to the integration of corporate and personal taxes.     

无住所个人税收负担变化分析

无住所个人在月收入相同的情况下,由于在华居留时间不同负有不同的纳税义务,其税收负担随在华居留的时间越长,月税收负担越重。本文根据相关文件,通过详细解析计算公式,并用实例分析了这一规律。     

美国州公司所得税制及其存废之争

本文首先介绍了美国州公司所得税制的概况,进而梳理了纳税人、立法机构、政府部门以及研究者对美国州公司所得税税制设计以及是否废除该税种的广泛争议,得出美国州公司所得税正在被逐渐边缘化的结论。     

公司型基金:中国基金业发展的战略选择

公司型基金现已成为世界基金组织模式的主流形式，而我国到目前为止全是单一的契约型基金。相对于契约型基金的固有缺陷而言，公司型基金有契约型基金无可比拟的制度优势。基于此，公司型基金应该成为我国未来基金业发展的主要政策取向。为此，必须在法律上明确界定公司型基金的法律性质以及处理好公司型基金与契约型基金的税负均衡问题。     

Information system and corporate income tax enforcement: Evidence from China

This paper adds the literature by investigating the effect of information system on corporate income tax (CIT) enforcement. We exploit the regional variations generated by the implementation in 2013 of the third stage of the China Tax Administration Information System (CTAIS-3) pilot. The CTAIS-3 is a nationally unified information system that significantly reduces information asymmetry between different tax authorities across regions. We find that the CTAIS-3 pilot significantly reduced firms’ conforming and non-conforming tax avoidance. The enhanced tax enforcement is particularly prominent if a firm is of a smaller size, or is administrated by the State Administration of Taxation, or is a non-state-owned enterprises, or locates in cities with a higher level of local fiscal pressure. Furthermore, we show that the CTAIS-3 improved the CIT enforcement by deterring firms from underreporting accounts receivable, as well as over-reporting accounts payable, inventory and the number of employees. In general, it would be more difficult for firms to hide profits from tax authorities under the CTAIS-3.     

欧盟税收管辖权的现状与趋势

欧盟有关税收问题的规定,约束了成员国的税收立法内容,并且已经超越成员国的独立税收管辖权,导致成员国税收管辖权部分转移,出现超越国家的税收管辖权现象。欧盟法律制度的主要目标之一就是消除统一市场的人为和制度障碍,促进共同市场内部的商品、劳动力、资本和服务流动。欧盟在处理与成员国之间的税收管辖权问题上已经取得了有益的进展,但是,税收管辖权由国家向国际组织行使的转变仍然任重道远。     

新企业所得税法的税收管辖取向

本文主要阐述了新企业所得税法的税收管辖取向,探究其与国际税收协定的冲突和协调,并就新企业所得税法对税收管辖权的运用进行了分析。     

"中性税收"范畴集的再造与理论推想

"中性税收"范畴是西方税收理论的核心内容。本文在剖析西方"中性税收"范畴理论局限性的基础上,以"超额税收与税收超额负担"概念为基础,提出了新的"中性税收"范畴集。新的"中性税收"涵盖适度税收、效率税收、宪政税收的基本特征,这一理论框架具有更强的理论包容性与政策应用性。     

IAS/IFRS in Belgium: Quantitative analysis of the impact on the tax burden of companies

The adoption of International Accounting Standards and the International Financial Reporting Standards (IAS/IFRS) in the European Union is part of the European Commission's global tax harmonisation policy whose aim is to establish a common (consolidated) corporate tax base. The paper shows that the impact of an IAS/IFRS-based tax accounting on the effective tax burden of Belgian companies is large and not uniform across sectors. Some sectors, like construction and automotive vehicles, experience much larger increases in effective tax burdens than others. Globally the impact is relatively important. The analysis is conducted using the European Tax Analyzer (ETA), a multi-period forward looking program. In a European context, an IAS/IFRS-based tax accounting will increase the effective corporate tax burdens in all selected countries. However, it will most probably maintain the current tax competitive positions of EU countries. The expected broadening of the tax base could constitute an opportunity to reduce the corporate income tax rate without changing the overall effective burden.     

The role of the european union in environmental taxation

The paper considers the extent to which environmental taxation should be coordinated by, or assigned to, the European Union (EU) rather than its member states. An economic interpretation of the principle of subsidiarity forms the main organizing principle for the discussion. Since the signing of the Maastricht Treaty in 1992, this principle has governed the boundary between the roles of member states and the Union. The paper considers the application of subsidiarity to the assignment of policy responsibility for environmental taxation between the EU and national governments, highlighting the role of both environmental and economic spillovers from uncoordinated national policy and problems of integration of environmental taxes with other areas of policy.     

From the global income tax to the dual income tax: Recent tax reforms in the Nordic countries

The paper discusses the recent drive toward a system of dual income taxation (DIT) in the Nordic countries. The pure version of this system combines progressive taxation of labor and transfer incomes with a proportional tax on income from capital at a level equal to the corporate income tax rate. The paper considers the motives for the introduction of this new income tax system, ranging from abstract theoretical arguments to very pragmatic considerations. While the Nordic DIT system violates the principles of the conventional personal income tax, it is argued that it may in fact be more in line with the philosophy of a true Haig-Simons comprehensive income tax. It is also suggested that the DIT system may cause fewer distortions to resource allocation than the conventional income tax. On the debit side, the paper points out several practical problems of taxing income from small enterprises under the differentiated income tax.     

"两法合并"前后税前扣除政策的比较

内、外资企业所得税合并(以下简称“两法合并”)之后,税前扣除政策的变化会对企业税收负担产生直接的影响。本文对工资费用、公益性捐赠、研发费用等方面的变化进行了比较系统的分析,并通过举例对比了“两法合并”前后应纳税额计算的差异情况。     

Dividend taxation and corporate investment: a comparative study between the classical system and imputation system of dividend taxation in the United States and Australia

In recent times a number of countries have initiated some important tax reforms to eliminate the distortions of double taxation. In this context, Australia adopted a dividend imputation system in 1987, while the US employed the 1986 Tax Reform Act (TRA). The analysis in this paper examines the effects on the level of corporate capital investment, on proxies for corporate tax rates, financial leverage, liquidity, capital intensity and firm size after controlling for the tax reforms. The empirical results provide evidence that: (1) dividend imputation as introduced in Australia is an effective way to reduce the distortions caused by the traditional system of taxation. (2) Compared with the TRA, dividend imputation has been better able to positively stimulate corporate capital investment. (3) TRA effect on corporate investment is more pronounced in the US for firms having a net operating loss. (4) Individual tax rates play a role in corporate investment decisions in both the US and Australia.