最优所得税理论与我国个人所得税的实践

最优所得税理论一诞生,就受到了广泛关注。一些学者用不同模型阐述了最优所得税理论。虽毋须严格按照这些模型来设计我国的个人所得税制度,但其模型所体现的税制设计理念或思想对现阶段我国个人所得税制度的设计具有一定的参考价值。     

Capital Mobility and Source-Based Taxation of Capital Income in Small Open Economies

This paper examines the taxation of capital income in a small open economy that faces a highly elastic supply of internationally mobile capital and increasing tax competition. The analysis considers a wide variety of additional factors that affect the determination of capital income taxation policy, including the desire to tax economic rents earned by foreign and domestic firms, the desire to take advantage of any treasury transfer effects, the role played by transfer pricing and other financial accounting manipulations by foreign multinationals, the need for a backstop to the personal income tax and various political concerns. The paper evaluates several potential income and consumption-based tax reforms in this context. JEL Code: H21, H25, H87     

Taxation of Interest Income

Why is interest income taxed so much more heavily than other forms of capital income? This differential tax treatment has generated substantial tax arbitrage, resulting in lower tax revenue, efficiency costs, and apparently net gains to rich borrowers and net losses to poor lenders, together suggesting that this tax treatment makes no sense on welfare grounds. In examining this argument more formally, this paper reveals two omitted considerations that can help explain the existing tax treatment. First, the forecasted increase in the market interest rate results in a redistribution from rich borrowers to poor lenders. Yet this redistribution comes at no marginal efficiency cost, starting from a situation with no distortions to portfolio choice, so at the margin dominates further redistribution through the income tax. In addition, information about an individual's portfolio choice reveals information about her earnings ability, even controlling for observed labor income, if those who are more able tend to be less risk averse. By making use of this extra information about earnings ability, the tax system can be better tailored to redistribute from able to less able, for any given efficiency cost.     

结合逃税的最优税收理论研究评述

最优税收理论主要研究税制的最优设计问题,而逃税理论主要致力于政府的最优执行问题,最近出现了将这两种理论结合起来的研究趋势。结合逃税的最优税收理论,包括最优所得税和最优商品税等内容,研究结果表明:结合逃税的最优税收理论并不能得出比标准最优税收理论更为明确的政策结论,其还有待于进一步的研究和发展。     

Optimal International Taxation and Growth Rate Convergence: Tax Competition vs. Coordination

Optimal international taxation and its implications for convergence in long run income growth rates are analyzed in the context of an endogenously growing world economy with perfect capital mobility. Under tax competition (i) the residence principle will maximize national welfare; (ii) the optimal long run tax rate on capital incomes from various sources will be zero in all countries; and (iii) long term per capita income growth rates will be equalized across countries. Under tax coordination, (i) becomes irrelevant while (ii) and (iii) will continue to hold. In other words, optimal tax policies are growth-equalizing with and without international policy coordination. This revised version was published online in July 2006 with corrections to the Cover Date.     

Why Capital Income Taxes Survive in Open Economies: The Role of Multinational Firms

This paper discusses the role of multinational firms and double taxation treaties for corporate income taxation in open economies. We show that it is optimal for a small open economy to levy positive corporate income taxes if multinational firms are taxed according to the full taxation after deduction system or the foreign tax credit system. Positive corporate taxes also occur in the asymmetric case where some countries apply the exemption system and others apply the tax credit system. If all countries apply the exemption system, the optimal corporate income tax is zero. We also show that, under tax competition, corporate income taxes are not necessarily too low from the perspective of the economy as a whole. While the undertaxation result is confirmed for the case of the exemption system, tax rates may also be inefficiently high if the deduction or the credit systems are applied.     

The European Commission's Report on Company Income Taxation: What the EU Can Learn from the Experience of the US States

The European Union Commission has proposed using consolidated base taxation and formulary apportionment to tax the EU-source income of multinational companies. This paper examines US state experience with a similar approach. Despite some positive lessons, especially the need to consolidate income of affiliated companies, lessons are mostly negative, especially regarding the choice of apportionment formula, the use of economic criteria to define the group whose income is to be consolidated, and complexity caused by lack of uniformity. US experience says nothing about using value added to apportion income—an approach that is conceptually attractive, but subject to transfer pricing problems.     

企业集团合并纳税：比较及启示

我国的合并纳税制度目前只针对特批企业,这不利于企业集团之间公平竞争。对企业集团合并纳税范围及不同国家合并纳税模式的比较与分析表明:我国应进一步完善所得税法等法律法规,保证税收公平,积极建设我国的"集团纳税制度"。     

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     

Tax Setting in a Federal System: The Case of Personal Income Taxation in Canada

In a decentralised tax system, the effects of tax policies enacted by one government are not confined to its own jurisdiction. First, if both the regional and the federal levels of government co-occupy the same fields of taxation, tax rate increases by one layer of government will reduce taxes collected by the other. Second, if the tax base is mobile, tax rate increases by one regional government will raise the amount of taxes collected by other regional governments. These sources of fiscal interdependence are called in the literature vertical and horizontal tax externalities, respectively. Third, as Smart (1998) shows, if equalisation transfers are present, an increase in the standard equalisation tax rate provides incentives to raise taxes to the receiving provinces. A way to check the empirical relevance of these hypotheses is to test for the existence of interactions between the regional tax rate, on the one hand, and the federal tax rate, the tax rate set by competing regions, and the standard equalisation tax rate, on the other hand. Following this approach, this paper estimates provincial tax setting functions with data on Canadian personal income taxation for the period 1982–1996. We find a significant positive response of provincial tax rates to changes in the federal income tax rate, the tax rates of competing provinces, and the standard equalisation rate (only for receiving provinces). We also find that the reaction to horizontal competition is stronger in the provinces that do not receive equalisation transfers.     

地方税制的国际经验与借鉴

本文通过对美、德、日、法四国的地方税制进行比较分析,归纳出四国地方税制的特征,并在此基础上提出了对我国地方税制改革的建议:建立分级地方税制;选择财产税为地方税主体税种;采用集权为主的税权模式。     

二元所得税的兴起:国际经验及启示

二元所得税作为一种对资本所得与劳动所得分离课税的个人所得税新模式,已被越来越多的国家所尝试。围绕二元所得税,理论界的争议主要集中于对资本所得征税的效率性、公平性、管理性和普及性等方面。对我国而言,既要反思劳动所得和资本所得的差异,明确个人所得税改革的基本思路与方向,又要采取渐进主义的改革策略,设计二元所得税的短期、中期和长期目标,在条件成熟时予以尝试。     

房地产税征收方案设计:收入分配效应及福利效应

以文献述评和2017年中国家庭金融调查数据为基础,设计由六档税率、三种免税方式、多项减免标准形成的126种房地产税征收方案,考察房地产税的收入分配效应和社会福利效应。结果表明：房地产税采用“面积+价值”综合免税方式的收入分配效应和福利效应较优。其中,减免面积标准须随税率提升而增加,福利效应受到免税方式、免税标准、税率及居民收入差距厌恶程度的综合影响。     

我国企业所得税境外所得抵免规定中存在的问题及对策

本文通过对现有境外所得抵免政策的分析,指明其需要补充和完善的内容,同时提出了相关政策建议。     

Taxation, Migration, and Pollution

This paper analyzes optimal fiscal, environmental and immigration policy for a single jurisdiction. In the presence of immigration quotas, taxes on the output of externality-producing industries should be higher than indicated by the standard rule for Pigovian corrective taxation. Immigration quotas are not optimal if fiscal instruments can be used to control immigration, and relaxation of immigration quotas generally increases domestic welfare. If optimal taxes are imposed on immigrants, no immigration quota should be imposed, and a version of the traditional Pigovian rule characterizes optimal taxation of domestic externalities. If production in the immigrants' country of origin causes trans-boundary spillovers, domestic welfare can be improved by lighter taxation of immigrants or by further relaxation of immigration quotas. This revised version was published online in July 2006 with corrections to the Cover Date.     

美国公司所得税制的实践及其对我国的启示

传统公司课税理论从法人性质角度说明公司负担所得税的合理性,但是这种解释方式受到了现行公司组织形式多样化的挑战。美国之所以对C公司、S公司、有限责任公司和开放式合伙采取灵活多样的所得税制,而不受纳税人是否具有独立法人资格的影响,乃是贯彻应能负税原则使然。在这一理论的指导下,并受国际上减轻经济性双重征税趋势的影响,我国对一人公司应改为采用单一课税模式。     

Intertemporally Dependent Preferences and the Welfare Cost of Capital Income Taxation

The welfare cost of capital income taxation is analyzed utilizing intertemporally dependent preference operationalized using a variable rate of time preference. It is shown that if households exhibit increasing marginal impatience, then the welfare cost of capital income taxation is inversely related to the elasticity of the rate of time preference with respect to consumption. Therefore, the welfare cost of capital income taxation reported using time additive preferences may not be robust. Numerical examples show that the use of time additive preferences could result in the welfare cost of capital income taxation to be overestimated by as much as 25%.     

美国劳动所得税抵免制度及其借鉴

美国的劳动所得税抵免制度不仅是一种税收政策,更是一种反贫困的福利政策。从效率角度看,劳动所得税抵免有助于促进低收入者参与劳动;从公平角度看,劳动所得税抵免有助于扶助低收入家庭和贫困儿童,且实施成本较低。本文通过对美国劳动所得税抵免制度的制定、实施方式、发展趋势和制度影响的分析,试图为我国的个人所得税改革寻找一种新的思路。     

Financing Public Goods with Income Taxation: Provision Rules vs. Provision Level

Due to the use of distortionary taxation, many believe that real-world economies should attain a lower level of public expenditures than in a situation where lump-sum taxes are available. The present paper examines this hypothesis by means of the two-type self-selection model of income taxation. Based on the findings of Boadway and Keen (1993), I provide sufficient conditions for both a lower and a higher level of public expenditures in second best than in first best. In particular, it is shown that the separability assumption of Christiansen (1981) leads to under-provision of the public good in the income tax optimum.     

Exemption vs. Credit Method in International Double Taxation Treaties

This paper examines the choice of international double taxation relief methods by two small countries that mutually exchange foreign direct investment. At the first stage, each country chooses between the exemption and the credit method (as prescribed by the OECD model treaty) and at the second stage, each country sets nationally optimal non-discriminatory capital tax rates. It is shown that in the subgame perfect equilibrium both countries choose the exemption method. Mutual application of the exemption method is also shown to yield the highest welfare for each country. While the tax export effect generally induces both countries to choose inefficiently high tax rates, this effect is weakest when both countries exempt foreign earned profits from domestic taxation.