浅谈房地产项目土地增值税的纳税筹划

对于房地产行业来讲,在近年来的发展中,国家出台了相关宏观政策,对该行业进行了调整,所以房地产企业的发展受到了一定程度的影响,许多企业在发展过程中由过去的粗放式管理模式向精细化管理模式转变。房地产企业在盈利的过程中,需要向政府及相关土地部门缴纳土地增值税,这对于企业自身的盈利能力以及现金流会产生较大的影响,所以房地产企业针对土地增值税进行纳税筹划具有非常重要的意义。论文以土地增值税纳税筹划的积极意义为出发点,论述了纳税筹划工作的原则及方法。     

浅谈企业的合理避税

随着我国市场经济的蓬勃发展,为使得利润最大化,如何降低成本,合法规避各种税金成为摆在企业面前的一个重要课题。本文在尊重税法、依法纳税的前提下,对合理避税的方法作了简要介绍。     

基于纳税会计的税收筹划探究

企业经营发展的主要目的是追求最大经济利益和不断降低企业经营成本,进而在激烈的市场竞争中占据有利地位,为此加强企业税收筹划至关重要。企业在对当前执行的会计准则和税收政策熟知情况下,对这些税收政策进行细致分析,并对相应会计准则进行有效运用,可以起到降低企业税负和增加企业利润的作用。基于此,论文对纳税会计基础上的税收筹划进行分析和探讨。     

油气田企业税收政策研究

随着石油工业的发展和勘探开发条件的变化,石油税收政策成为影响石油工业乃至整个国民经济发展的重要因素。如何通过制定合理的税收政策,鼓励和促进我国陆上石油资源的勘探与开发,增加油气资源供给,对于我国石油的安全供应和经济的稳定发展具有举足轻重的意义。本文针对我国陆上石油资源的特点,在总结我国石油税制历史沿革的基础上,通过分析我国油气田企业税制中存在的主要问题,提出我国税制改革的相关建议。     

TAX COMPETITION AS A CAUSE OF FALLING CORPORATE INCOME TAX RATES: A SURVEY OF EMPIRICAL LITERATURE

Abstract Since the mid 1980s, tax rates on corporate income have declined in most industrialized countries. Tax competition between countries for mobile capital has frequently been mentioned as an explanation for this development. A vast empirical literature dealing with tax competition for mobile capital has emerged. This paper categorizes and summarizes the existing empirical studies on this issue. Particular focus is placed on the isolation of the substantive implications the quantitative study outcomes convey. Given the empirical evidence surveyed, it appears that tax rates indeed decline due to tax competition between countries, and in particular due to competition for profits. In addition to summarizing the substantive implications of the existing empirical literature, the paper addresses the question of whether the existing studies can convincingly isolate tax competition as a driver of falling corporate income tax rates.     

Natural environmental disclosures: strategic responses by Port Moresby Stock Exchange entities

This paper discusses the components of a simplified natural environment disclosure (NED) index that accommodates a developing country setting, and examines the level of NED in annual reports of all Port Moresby Stock Exchange (POMSoX) entities of Papua New Guinea for 2002. The results of the study found a low level of NED consistent with what Brown and Tower (2002) coin a traditional reporting model, although POMSoX entities showed a much higher level of NED than their Pacific Island Country counterparts. A number of conventional accounting predictors were put forward to explain the level of NED. None of the predictors explained aggregated NED, but some of the predictors, most notably stock exchange listing, explained some individual components of NED. The very low level of NED flies in the face of much natural environmental regulation in PNG. Clearly, POMSoX regulations, POMSoX entities and international accounting advisers need to focus on the reporting of natural environmental issues if environmental accounting is to take shape in this part of the developing world. Copyright © 2006 John Wiley & Sons, Ltd and ERP Environment.     

供给侧结构性减税降费的思考

根据新供给经济学的观点,刺激经济发展最有效的手段是减税降费,因为减税降费不仅可以使企业降低成本、增加利润,进而扩大生产规模和投资科技创新领域,而且可以增加员工收入,提高员工积极性,使其更好地投入生产,这与供给侧结构性改革侧重于对生产者的激励不谋而合。中国经济进入新常态后,出现了如产业结构不合理、创新能力不强等问题,而需求侧宏观经济政策不能解决这些问题。基于此,论文就供给侧结构性减税降费进行了思考。     

Tax‐avoidance strategies of American multinationals: an empirical analysis

This paper analyzes the opportunities of American multinationals to reallocate their profits into tax havens. In contrast to previous papers, a comprehensive look on the profit‐shifting process is undertaken by proposing three different tests. Multinationals in high‐tax countries have a lower equity ratio than affiliates in tax havens, indicating that income is shifted by extensively financing subsidiaries in high‐tax countries with debt. Furthermore, the share of retained earnings is lower in high‐tax countries owing to the unattractiveness of tax deferral. When testing for the outcomes of profit shifting, the results show that the pre‐tax profitability of American multinationals is higher in tax havens. This relationship is consistent with the opportunities of multinationals to shift income outside high‐tax jurisdictions. Finally, the paper shows that profit shifting largely takes place into tax havens, whereas other countries do not benefit from profit‐shifting activities. Copyright © 2009 John Wiley & Sons, Ltd.     

关于国际避税主客观原因的分析

跨国纳税人在进行经营时利用国际避税来实现自己的最大利益．纳税人进行国际避税的主观原因在于追求经济利益最大化，客观原因则是多方面．如各国税收制度的不同、各国税收管辖权的选择不同和各国税收征管技术水平的差异等。进行避税原因的分析有助于维护国家利益和保证国际贸易的正常进行。     

Exchange rates, tax-subsidy schemes, and the revenue from foreign trade in a centrally planned economy

Conclusions It has been argued that while in the traditional analysis of the classic CPE the exchange rate has only an accounting function, inappropriate methods of national income accounting can lead to changes in the exchange rate generating changes in the real economy, provided that trade in unbalanced in foreign currency prices. This thesis was explored by examining the way the profits from foreign trade were calculated by the Ministry of Foreign Trade, and then transferred to the state budget. It was shown that the correct measure of the state's increased command over domestic resources from engaging in foreign trade, derived from the implicit taxes on that sector, was the ministry's profits on its domestic operations, the first term in (2). However, evidence was presented which suggested that its profits on foreign currency account measured in domestic currency, the second term in (2), were also passed over to the state budget. This implies that transferred profits from foreign trade will overstate the underlying command over resources when there is a balance of payments surplus, and understate them when there is a deficit. The consequence of this is that the domestic economy faces a series of erratic, though small, inflationary and deflationary impulses, regardless of changes in the exchange rate.The theoretical role of the preisausleich system was explored in some detail and it was argued that, although the system has been designed to insulate the domestic economy from external disturbances, there were clear reasons why it had come to play a major part in revenue raising. Specifically, it is administratively convenient to tax resources at their point of entry into or exit from the economy; the taxation of foreign trade widens the tax base and reduces the visibility of the tax system. But, of course, this grafting onto the preisausgleich of a second major function of revenue raising does lead to the development of a further channel through which external disturbances can pass into the domestic economy. That is external disturbances impact on the domestic economy not only through the production and welfare effects of changing exports and imports, and through whatever tenuous links are allowed between foreign and domestic prices, but also insofar as those disturbances affect the ministry's profits from foreign trade. In short, foreign economic disturbances show up in variations in the position of the non-inflationary government budget constraint. To that extent the second function of the preisausgleich impairs its ability to perform its original insulation function. In a minor way, the successful non-inflationary performance of the insulation function has always required adjustments in the government budget constraint. But the growth in the importance of foreign trade taxation has magnified the importance of this phenomenon, and led to a trade-off between the two functions.University of Bath. Initial research for this paper was carried out under ESRC grant HRP 7417/1.     

A computer model for the financial analysis of urban housing projects

A financial analysis model has been implemented within the framework of the APL time-sharing system. The model allows different levels of input and output commands which can be used by persons with different degrees of familiarity with computing, in general, and the APL System in particular. It is the result of a joint study between IBM and the Urban Coalition aiming at providing a computer model of the urban housing process which would allow both government planners and private developers to analyze the financial prospects of individual housing projects under a variety of subsidy provisions and other constraints such as FHA regulations concerning profits. The model includes provisions for different types of sponsors of urban housing projects allowing for different tax treatment of profits and losses, and different formulas for estimating the rent charged. The basic output is either in the form of a summary of financial figures or complete financial tables such as income statements, balance sheets and cash flows.     

Corporate investment,dividend decisions,differential taxation and the no-arbitrage condition

Masulis and Trueman (1988) investigated corporate investment and dividend decisions under differential personal taxation. They assumed investors in different tax brackets, a state-preference complete market (which includes pure securities for each state) with a ban on short-selling. They concluded that shareholders prefer non-zero dividend payment. In their model, the restrictions on short-sales were needed to bound tax arbitrage profits, among investors in different tax brackets, so that equilibrium could be reached. However, the joint assumptions of complete markets, and restrictions on short-selling, are inconsistent. By utilizing more recent results, from the tax arbitrage literature, we allow short-selling, and examine the role and implications of the no-arbitrage condition. We show that, with investors in different tax brackets, equilibrium is feasible. We conclude that a revised Masulis and Trueman type model does not explain a non-zero optimal dividend policy.     

General equilibrium and optimal taxes

It is shown that if subsidies are not excessive, there exists a general competitive equilibrium in the presence of a complex tax structure. Furthermore, under certain continuity assumptions, a tax structure which is optimal from the social point of view can be determined. Procedures maximize quasi-concave after tax profit functions. Consumers have convex budget sets reflect- ing their income from sales and profits minus taxes on fixed income and progressive sales taxes. Their preferences are interdependent, intransitive and incomplete. The government provides public goods and determines the optimal tax regime on the basis of its preferences on the final competitive consumption allocation.     

我国证券市场中的所得税问题研究

欧美和日本等国家的上市公司偏好于债务融资,而我国的上市公司在进行融资决策时普遍采用"轻债务重股权"的方法。本文认为这主要是因为我国的所得税制中存在对股权收益的部分征税、重复征税,对证券的投资收益和转让利得实行差别税收政策,以及存在非债务税收保护措施等,所以必须有针对性地改革现行税制,对股息所得征税遵循"同股同利"的原则,清理不恰当的非债务税收保护措施,减轻对股利的重复课税以及改革证券市场的资本利得税。     

Problems in Acquiring Mineral Revenues for Financing Economic Development: A Case Study of Zambia During 1970–78

A bstract . During the 1970s Zambia granted tax incentives to transnational mining companies (thereby foregoing some revenue ) in order to achieve expected investment benefits to the economy and government. The Government also acquired ownership interests in the companies via asset acquisition. Global market forces turned against Zambia's interests, and expected benefits were not forthcoming because company profits had become the sole tax base in the mineral sector. Zambia's experience from 1970 to 1978 suggests that it and other mineral export countries should (a) evaluate carefully whether reducing the effective tax rate on company profits actually induces investment , and (b) consider thoroughly whether a tax scheme that includes a proper mix of profit, mineral and export levies is more appropriate than a single tax base.     

The new view of the property tax A reformulation

The ‘new view’ of the property tax is reformulated within the context of a model with interjurisdictional competition, endogenous local public services, individuals who are segregated into homogeneous communities according to tastes for local public services, a simple form of land use zoning, and a political or constitutional constraint on the use of head taxes by local governments. Expressions for the ‘profits tax’ and ‘excise tax’ effects of the property tax are derived. The effects of a ‘consumption distortion’ away from government services due to local reluctance to tax mobile capital are also examined.     

A model for analyzing the external effects of new towns on regional development

Title VII of the New Communities and Urban Growth Act of 1970 enables the Department of Housing and Urban Development to guarantee bonds used to finance New Town development by the private sector. Large scale New Town development may drastically affect regional land use patterns. New Towns may siphon resources away from central cities, reducing their tax base, increasing their ghettos and accelerate urban decay. The model proposed in this paper is designed to analyze the effect of subsidized New Towns on a region's growth. The output of the model would enable the policy makers to expand their decision horizon in evaluating bond guarantee applications. The model is composed of four integrated submodels; a national dynamic input-output model, an interregional forecasting model, a Lowry type land use model and a financial evaluation model.     

关于“营改增”后的账务处理

国家为了增强服务行业的竞争力,对原来交营业税的一些行业比如软件开发、运输、咨询行业等8大行业进行交增值税的试点,由于营业税和增值税的性质不同,差额纳税的税务处理为可抵减销售额,这样的目的,从总体上来说是降低接受服务方的税负,现就营改增后的会计账务处理阐述笔者的观点。     

A study on the incentive compensation structure with payroll tax: A continuous-time principal-agent model

This paper studies a case when the government levies a payroll tax on the employee (agent) of an enterprise. We use a continuous-time principal-agent framework to analyze the impact of the tax on the employee’s working strategy and derive an incentive compensation scheme. The agent is supposed to be aware of his pre-tax and after-tax salary. Under the theory of behavioral economics, loss caused by taxation is taken into consideration. The Hamilton-Jacobi-Bellman (HJB) equation of principal’s profits is derived. By exploiting the HJB equation, we get several properties of the optimal contract. We also perform comparative statics to show our results. The model suggests that the agent’s utility loss enlarges as the tax rate increases. However, an increase in the tax rate does not always decrease principal’s profits.     

跨国公司转让定价避税与反避税研究

转让定价是跨国公司实施的最主要的转移利润的手法。随着越来越多的跨国公司将在中国设立并发展,对于部分跨国公司通过国际转让定价对我国税基造成的损害,更应该引起重视。从税务当局的角度研究转让定价与反避税问题,成为税收研究和企业管理的一个重要课题。