现行企业所得税优惠政策评析

现行企业所得税制度已经运行十年有余,作为非基准税收制度的所得税优惠政策也越来越多,并且其执行效果不尽如人意。通过对现行所得税优惠的政策制度基础进行分析,可得出如下基本判断:两税并存是我国高税率、多优惠的制度基础;作为非基准税收制度的所得税优惠政策对基准所得税制度修订过多,税制的改革已成为必要;改革的方向是两税并轨,清理优惠,对于需要保留的税收优惠政策应贯彻以行业优惠为主、区域优惠为辅的原则。     

Reduced Tax Progressivity in Norway in the Nineties: The Effect from Tax Changes

The inequality in pre-tax income increased in Norway in the 1990s, while the concentration of taxes remained largely unaltered. This means that tax progressivity has decreased in the period, as measured by summary indices of tax progressivity. In this paper I analyze individual income data to ascertain whether tax changes in the period can explain the observed decrease in tax progressivity. As marginal tax rates at high income levels have been substantially reduced in the period, for instance through the tax reform of 1992, it is expected that tax changes may have influenced the degree of inequality in pre-tax incomes. This behavioral effect is examined by deriving estimates of the elasticity of gross income with respect to the net-of-tax rate, obtained from various panel data regressions. The tax changes may also have shifted the distributional burden of taxes for unaltered level of pre-tax income inequality. In order to identify this (direct) effect of tax-law alterations, the same fixed distribution of pre-tax income is exposed to various tax-laws in the period.     

Tax without Design: Recent Developments in UK Tax Policy

This paper considers the development of tax policy in the UK over the last decade or so and assesses policy change against a low bar – consistency and coherence. While this government has followed some consistent policies – notably, in some aspects of corporation tax and in increasing the income tax personal allowance – there are few signs of a wider coherent strategy. The same has been true of other recent governments. Many aspects of the system have become more complex. There have been numerous policy reversals. And few of those aspects of the system in most need of reform have been tackled. The need for reform, and a clear strategy for reform, remain as pressing as ever.     

Punishing in the public interest: Exploratory Canadian evidence pertaining to convictions and incarcerations for tax offences

Although naming and shaming is a deterrence strategy used by tax authorities, ostensibly to increase tax compliance, the contents of tax conviction notices in which taxpayers are named and shamed have not been investigated in empirical research. To this end, this study uses a sample of 2,570 taxpayers convicted of tax offences by the Canadian tax authority over a ten-year period (2006 through 2015) to identify key characteristics of convictions and incarcerations for tax crimes, and to understand how key conviction characteristics are associated with incarceration. Over this period, findings show that 55% of tax convictions in Canada relate to failure to file tax returns, and that 14% of convicted individuals are incarcerated for an average of 17 months. The mean unreported income per convicted taxpayer is $89,978, the mean unremitted excise tax per convicted taxpayer is $15,330, and the mean fine amount per convicted taxpayer is $48,201. Males are more likely to be convicted of a tax crime than females. Further, professionals are far more likely to be incarcerated than non-professionals. Results also indicate that underreporting related to excise tax as a form of tax evasion is more likely to result in harsher sentencing than underreporting related to income tax. Lastly, we observe a downward trend in convictions and incarceration over the 10-year span, such that the total convictions and incarcerations at the end of the sample period are roughly one-third of the convictions at the beginning. Implications for public policy are discussed.     

Simplifying the personal income tax system: lessons from the 1998 Spanish reform

Governments often try to reduce the complexity of personal income tax systems by decreasing the number of tax filings. The 1998 reform of the Spanish income tax system has followed this approach by adjusting withholding on earned income to the income tax liability. In this paper, we assess to what extent the reform has fulfilled its purposes, making use of a micro‐simulation tax‐benefit model for Spain, ESPASIM. The number of individuals exempt from filing a tax return has been reduced to around half of the total number of taxpayers. However, the quantity of tax returns sent to the tax administration has not changed so much because the new withholding system adjusts taxes for only 29 per cent of those exempt. Moreover, the new system increases the overall excess of tax withholding by 1.5 billion euro. We also study alternative reforms that could achieve better results than the one implemented.     

The role of political elites in income tax system design and tax fairness

Given the importance of fairness in the public acceptance of tax systems (Mirrlees et al., 2011), understanding the role of political elites in the tax design process and how this impacts fairness is important. In this paper, we use an interpretative approach to examine the design and ultimate rejection of the Kansas tax policy experiment that ran from May 2012 to June 2017. The central design element of this experiment was the fundamental disruption of the long-standing principle of horizontal equity (fairness), in which non-wage business income was relieved of income tax, while wage income was taxed. By interpreting this experiment through a Bourdieusian lens, we identify five key themes that are helpful in understanding income tax design, tax fairness, and the role played by political elites. Overall, we contribute to the literature by highlighting the way in which cultural capital may be used by political elites to reformulate groups of taxpayers in order to justify unequal treatment of equal taxpayers, which represents a violation of the notion of horizontal equity (fairness). We also highlight that although such violations of fairness in income tax system design may be sustainable in the short run, over the longer term, notions of fairness are so deeply embedded in the habitus of individual taxpayers that a return to the status quo is likely.     

新个税法模式下的劳动者权益探究

"公平"是税收环节开展与劳动关系平衡的交叉范畴,依附于人身属性以获取财产性利益的劳动者在个人所得税缴纳中占主体地位,工资薪金所得更是个人所得税的丰厚税源。新个税法由"分类税制"向"分类-综合并行二税制"模式转变,以实现对横向税负公平与纵向税负适度的保障,通过劳动性所得综合征税设置、综合所得税率调整、费用扣除标准设计三个主要方面调节劳动者权益杠杆,影射出对公民权利与义务的对等性追求。新个税改革无论在个税税制模式上抑或是税率级距设置上无不体现着对中低收入群体的福利关怀。     

Income Shifting in the Spanish Dual Income Tax*

Based on a model of behavioural response to taxes, and using the Taxpayers Panel from the Instituto de Estudios Fiscales for the period 1999–2009, we analyse whether the dual nature of the Spanish personal income tax (PIT), reinforced by the 2007 reform, has influenced taxpayers’ behaviour, causing them to convert part of their ‘general income’ (from labour, real estate or economic activities) into ‘savings income’ (from movable capital or capital gains). We also extend the analysis of income shifting and study whether Spanish taxpayers also responded to the different tax treatments given to the two types of savings income (from movable capital and capital gains) until 2007, transforming savings income from one type to the other. The results of our study demonstrate three facts. First, Spanish taxpayers did respond to the different tax rates, shifting income from the general base to different forms of savings, especially capital gains. The highest‐income individuals and the self‐employed and business owners are the groups where this behaviour was most marked. Second, the self‐employed and business owners also turned income from movable assets into capital gains, guided by their different tax rates. And third, we find signs of ‘anticipation’ and ‘learning’ effects caused by the 2007 tax reform. We believe that the results obtained will enrich the growing literature on income shifting.     

论个人所得税的二元课税模式

由于综合个人所得税制在理论基础和实际征管方面都存在着难以克服的困难,发端于北欧国家的对劳动所得适用累进税率而对资本所得适用比例税率的二元个人所得税制就成为一种较为现实而理想的模式,在国际上正得到日益广泛的支持。我国近年提出的综合与分类相结合的个人所得税制模式近似于二元所得税制,应当作为个人所得税改革的长远目标,但还需对具体制度安排进行恰当的设计。     

Decomposition of progressivity and inequality indices: Inferences from the US federal income tax system

Vertical equity is an important criterion in evaluating a tax system. Vertical equity has two elements: progressivity and income equality. In this paper, we analyze the vertical equity effects of the US income tax system during 1995–2006 and show that income inequality increased substantially during the period combined with a significant reduction in real progressivity.     

税收规避与财务报告成本的权衡研究——来自中国2008年所得税改革的证据

本文以我国2008年所得税改革为契机,借鉴Shackelford和Shevlin(2001)的税与非税因素权衡模型,实证考察有减税预期的上市公司在税收规避中是否权衡了财务报告成本。本文发现,有减税预期的公司存在将减税之前期间的利润推迟确认到未来低所得税率期间的盈余管理行为,且为避免这一行为过于明显而遭致惩罚,利润跨期转移的期间宽度较长。但有着高财务报告成本的公司明显降低了这一跨期利润转移的动机。研究证实了我国上市公司在税收规避决策中权衡了税与财务报告成本。研究结论有助于进一步丰富盈余管理文献,对当前我国税收制度改革具有一定参考意义。     

On the optimal progressivity of the income tax code

This paper computes the optimal progressivity of the income tax code in a dynamic general equilibrium model with household heterogeneity in which uninsurable labor productivity risk gives rise to a nontrivial income and wealth distribution. A progressive tax system serves as a partial substitute for missing insurance markets and enhances an equal distribution of economic welfare. These beneficial effects of a progressive tax system have to be traded off against the efficiency loss arising from distorting endogenous labor supply and capital accumulation decisions.Using a utilitarian steady state social welfare criterion we find that the optimal US income tax is well approximated by a flat tax rate of 17.2% and a fixed deduction of about $9,400. The steady state welfare gains from a fundamental tax reform towards this tax system are equivalent to 1.7% higher consumption in each state of the world. An explicit computation of the transition path induced by a reform of the current towards the optimal tax system indicates that a majority of the population currently alive (roughly 62%) would experience welfare gains, suggesting that such fundamental income tax reform is not only desirable, but may also be politically feasible.     

The effects of tax rate changes on tax bases and the marginal cost of public funds for Canadian provincial governments

The efficiency losses from taxation vary directly with the responsiveness of a government??s tax bases to tax-rate increases. We estimate the dynamic responses of tax bases to changes in tax rates using aggregate panel data from Canadian provinces over the period 1972 to 2006. Our preferred empirical results indicate that a one percentage point increase in corporate income, personal income, and sales tax rates is associated with a 3.67, 0.76, and 1.17 percent reduction in their respective tax bases in the short run. The corresponding long-run tax base semi-elasticity estimates are higher: ?13.60, ?3.63, and ?3.18, respectively. We use the tax base elasticity estimates to calculate the marginal cost of public funds (MCF) for the provinces?? three major taxes. Our computations indicate that the corporate income had the highest MCF and that the sales tax had the lowest MCF in all provinces in 2006. The MCF for the personal income tax ranged from 1.44 in Alberta to 3.81 in Quebec. Our results imply that there would have been significant welfare gains in 2006 from reductions in provincial corporate income tax rates. Our computations also indicate that the equalization grant formula may reduce the perceived MCF of the provinces that receive these grants, and that increases in provincial corporate and personal income taxes can cause significant reductions in federal tax revenues.     

Reinventing the Dutch tax-benefit system: exploring the frontier of the equity-efficiency trade-off

European governments aim to raise labour supply, cut unemployment and, at the same time, maintain social cohesion. Yet, economists have stressed the trade-off between these objectives. This paper reviews the key policy insights from optimal tax theory to identify options for reform in the tax-benefit system that can potentially improve the equity-efficiency trade-off. Using a comprehensive applied general equilibrium model, we then explore whether reforms along these lines in the Dutch tax-benefit system raise employment without sacrificing equality. The analysis reveals that selective tax relief for elastic secondary earners and low-skilled workers have this potential. A flat income tax structure, possibly combined with a negative income tax, worsens the equity-efficiency trade-off.      

我国个人所得税后续改革中必须考虑的若干问题

我国工资薪金个人所得税扣除额宜实行分地区浮动制度,而扣除额的调整必须与扣除方式的改革相结合才具有实质意义。从目前的征管实践来看,加强个人所得税管理、有效控制税源是确保改革目标实现的关键。此外,单纯追求个人所得税的公平功能而忽视其效率的作用,对我国社会政治经济的发展将产生不利的影响,也不符合改革的目标。     

权衡中的创新——双元所得税评介

双元所得税是与综合所得税、单一税并列的一种个人所得税的主要模式,其特征为双元税基、双元税率和限制优惠。双元所得税的优点是兼顾了税收收入和国际竞争力、兼顾了效率和一定程度的收入再分配、避免了对资本的重复课税、降低了由于通货膨胀带来的对资本所得的过度课税、简化了税制。双元所得税契合了北欧各国社会经济状况对税制的要求,因此,成为北欧国家个人所得税的首选模式。     

个人所得税功能分析及政策选择

个人所得税是目前增长最快的税种之一 ,是政府用来干预、调节经济活动的重要经济杠杆和调节社会收入分配的重要工具 ,在发挥其作用的同时 ,却产生了对劳动力和私人储蓄的替代效应 ,从我国近几年的运行状况来看 ,个人所得税无论是从税制的最初设计还是征管方面存在着严重不足 ,在政策选择上宜采取综合所得征收制及双向申报制     

Neutral Taxation of Shareholder Income

A Norwegian tax reform committee recently proposed a personal tax on the realized income from shares after deduction for an imputed risk-free rate of return. This paper describes the design of the proposed shareholder income tax and shows that it will be neutral with respect to investment and financing decisions and decisions to realize capital gains, provided that full loss offsets are granted. Thus the tax allows some non-distortionary double taxation of corporate equity income. With an appropriate choice of tax rates, it also solves the problem of income shifting under a dual income tax. JEL Code: H24, H25     

台湾地区所得税制度及其启示

本文对中国台湾地区所得税制度的演进、发展及立法政策精神进行了深入的理论分析,从税收一体化的角度对未来中国大陆地区所得税改革进行了展望,并提出了切实的政策建议。     

“十四五”时期的个人所得税改革展望

个人所得税在调节收入分配、实现社会公平方面具有重要作用。“十四五”时期的改革部署中明确提出了健全直接税体系,提高直接税比重的要求。因此,“十四五”时期个人所得税改革的重点在于提高个人所得税收入占税收总收入的比重,同时实现税收公平目标。对比近两年国外个人所得税发展趋势,发现我国个人所得税存在收入占比较低、劳动所得税负较重等问题。可以从多方面入手解决问题。一是将资本所得纳入综合所得计税范围,同时推进现代化税收征管,避免税收流失,以提高个人所得税收入占税收总收入的比重。二是通过完善专项附加扣除政策,进一步降低中低收入群体的税收负担,实现税收公平。三是优化高端人才税收优惠政策,提高人力资本积累对高质量发展的贡献。