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。     

Site Value Taxation and the Timing of Land Development

A bstract . Recent writers have challenged the traditional view that a tax on site value is neutral, but there is still disagreement as to the effects of the tax. The site value tax affects the timing of land development in that it provides an incentive for landowners to develop land sooner than under a property tax levied on improvements also. Confusion has resulted from a failure to distinguish market value from development value. The incidence of the site value tax must take into account the dynamics of untaxing capital and of the capitalization of the tax increase on land values , as well as of the resulting increase of land supply and its effect in further reducing land values. The increased profitability of capital improvements could then increase land rent from the demand side. Obviously, amidst such dynamic changes, the overall effect on land values and rents is unsettled pending further research.     

Housing as an asset and the effects of property taxation on the residential development process

A model of residential development is constructed recognizing the asset side of land and housing. The equilibrium process is characterized under the perfect foresight assumption, and the effects of a capital gains tax (both unanticipated and anticipated) and a tax on property values are examined.     

Property taxes and the timing of urban land development

This paper develops an optimal timing model which extends our understanding of the effects which property taxes have on the timing of land development. Comparative static effects of changes in property tax rates are investigated and policy rules are developed for the use of differential pre- and post-development tax rates to affect the timing of development. Changes in the property tax rate are found to be non-neutral with respect to the timing of development in most cases, accelerating or delaying development depending upon specific market conditions.     

Three-rate property taxation and housing construction

This paper examines the effect of property taxation on housing construction. In 2001, Finnish municipalities were allowed to levy an extra property tax on undeveloped land zoned for housing. Municipalities that adopted the new tax instrument have a three-rate tax property tax system with different tax rates on land before development, land after development and buildings. The remaining municipalities have a two-rate system with a uniform land tax and a building tax. A theoretical model of decisions by landowners suggests that the pre-development land tax ought to lead to faster development, but also the density of development may be affected. In the two-rate system land tax is neutral. The empirical results suggest that landowners respond to the tax incentives. Municipalities that adopted the three-rate property tax system saw an increase in single-family housing starts of roughly 12 percent.     

The Relative Efficiency of Taxes in a Two-Period Model of Urban Growth

In this paper we investigate the differential effects of a wage tax and a land value tax on urban development and economic efficiency. A two-period model has been used to confirm that while a land value tax is distortionary, a wage tax of equal yield is even worse at the level of a single open city where the supply of labor is perfectly elastic to the city. This result suggests that the finding land value taxes are distortionary is of little practical significance.     

土地使用管制及其利益补偿研究评述和启示

土地使用管制是政府配置土地资源、干预土地市场的一种方式。纠正土地使用的外部性、提供公共产品是管制的主要目的。土地使用管制的存在是必要的，但是人们必须注意加强对其效果的研究。这些效果有些是积极的，有些是消极的。土地使用管制本身是有成本的。随着社会的发展，土地使用管制方式越来越多样化、弹性化和市场化。由于管制而给有关主体造成的影响可通过税费或者补偿的方式予以再调整，以维护社会公平，并达到特定的社会目标。本文通过对国内外有关文献的回顾，得出了几点对我国土地制度有益的启示，这些制度包括耕地保护制度、用途管制制度和城市土地出让制度。     

Land Value Taxation and Housing Development

A bstract . The effects of land value taxation on housing development are studied in three disparate cities: Pittsburgh, McKeesport, and New Castle, Pennsylvania. These places are examples of three different types of city: central city, suburban city , and relatively isolated city , respectively. Shifting taxes from buildings to land is hypothesized to have different effects in the different types of cities. A liquidity effect , due to increases in the land tax rate , is expected to operate in all three types of cities. An incentive effect , due to decreases in the tax rate on improvements , is expected to function in central cities and, possibly, in relatively isolated cities. It is not expected to be important in suburban cities such as McKeesport. An incentive effect was found in Pittsburgh, but not in the other two cities. No evidence of a liquidity effect was found in any of the three cities. An explanation of why observed effects may not conform with hypotheses is given.     

Property Tax and Housing Returns

This paper evaluates the effects of property tax on housing. While land tax and capital gains tax are widely used for curbing hoarding of land and speculation, its effectiveness is inconclusive. The imposition of a capital gains tax will impair the liquidity of property transaction, lower the rate of return on property investment, and reduce revenue from land sales which represents an important tax resource for the communities. This paper shows that a capital gains tax is capitalized into housing prices. Individuals tend to postpone the purchase of houses because of transaction taxes. Using an impulse response function, we show that a transaction tax has a dynamic negative impact on housing returns. While this paper focuses on Hong kong, for the purpose of comparison Singapore and Taiwan are also discussed.     

The Impact of a Graded Tax on a Rural Area: A Case Study in Indiana County, Pa.

Abstract . The graded tax is a reform of the property tax which would tax land values at a higher rate than improvements in or on the land. What would be its impact on different types of rural owners of real property? A study of rural Indiana County, Pennsylvania, by William Ritter shows that the impact would vary according to the level of development the individual tract or parcel has undergone.     

The Economic Effects (Neutrality) of Taxes on Land

A bstract A recent review of the economic effects of land taxation by Steven Bourassa created the misleading impression that a tax on land will have pro-development or non-neutral effects where there are non pecuniary returns from land or where there are capital market imperfections preventing developers from obtaining all the land that they want for development This note argues that a tax on land value is generally neutral, and that this will be the case whether or not there are non pecuniary returns and capital market imperfections, provided that the existence and extent of the imperfections are independent of the tax     

Political Economy of Property Tax Reform: Hawaii's Experiment with Split‐Rate Property Taxation

Economic theory suggests that switching from a general property tax to a split‐rate tax increases land use efficiency and stimulates urban core development while preserving the environment and reducing urban sprawl. Under split‐rate property taxation, land is typically taxed at a significantly higher rate than improvements. Beginning in 1965 Hawaii experimented with a statewide split‐rate property tax system to encourage economic growth and effect land reform. The experiment was ended in 1977. Following the transfer of property taxing powers to the counties in 1978, some counties brought back the split‐rate property tax at times. Since 2006, Kauai County has adopted the unusual practice of taxing improvements at a higher rate than land for most property classes. This article chronicles and explains the rationale behind Hawaii's state and county experiments with split‐rate property taxation.     

Taxation for Low Cost Wood Fiber*

Abstract . If forest industry taxation is to be put on a sound economic basis, the Federal Government, the largest land owner, should pay the same taxes as any other landowner, so that the social and economic effects of taxation are realized. Specialists report that the form of the property tax preferred for the taxation of the property of the forest industry, under most circumstances, is land value taxation, not the property tax based on income realized at some point In the future which presumed the continued existence of virgin forests. This paper recognizes that the forest industry now is based on harvests of tree crops and proposes a further development of the land value taxation principle in the form of a forest tax composed of a land value tax combined with a tax on tree growth which increases as growth as a percentage of volume growth decreases with the tree's increasing age.     

Agricultural Land Conversion and Inheritence Tax in Japan

In this paper we investigate theoretically the extent to which the development timing of agricultural land conversion would be hastened by the introduction of inheritence tax. We extend the optimal timing of wealth maximizing value use models by Scouras (1978), Anderson (1993) and Kanemoto (1996) to examine cases where tax rates vary according to land use with (i) almost no income and (ii) high income use, such as rental housing. We first model landowner's behavior within the life cycle dynamic optimization framework and then simulate the impact of inheritence tax on the optimal timing of development. Some notable predictions about optimal timing of development emerge from our numerical analysis: no inheritence tax effect is observed for landowners whose inheritence probability is less than 1% (that is, landowners in the age group 40 or below) and whose inheritence tax rate is less than 10%. However, the optimal timing of development drops to below one year for landowners whose inheritence probability is more than 18% and whose tax rate is 30%.     

Income taxes and urban spatial structure

This paper examines the impact of an income tax in a monocentric city where households equilibriate their allocation of time between work, commuting, and leisure. An increase in the income tax rate lowers the implicit value of time, and hence transportation costs. “Compensated equilibrium” comparative statics analysis shows that under certain conditions, this results in a larger, more dispersed urban area, with lower land rents at the city center and less population within any given distance from the center. The welfare effect of an income tax rate change is also studied, and an expression for the marginal excess burden is derived. The income tax produces welfare losses both because it induces substitution in favor of leisure and in favor of travel—the latter accompanied by excessive spatial dispersion and consumption of space. The marginal excess burden depends not only on the compensated demand elasticity for leisure, but also on that for space. Finally, the problem of benefit measurement for transportation projects in this tax-distorted spatial economy is examined. Benefit measures should be deflated to adjust for the fact that further transportation improvements lead to reduction of land use intensity, exacerbating the problem of spatial resource misallocation in an already excessively dispersed urban area.     

Do Corporate Tax Concessions Really Matter for the Success of Free Economic Zones?

Not only a large number of developing countries but also transition economies have established free economic zones (FEZs) with the aim of attracting foreign capital by providing tax incentives, creating employment opportunities, and promoting exports and regional development. Tax investment promotion schemes include profit tax exemption, free or accelerated depreciation, investment tax allowance, subsidy for investment costs, etc., the effects of which on firms investment decisions can be compared based on the net present value model. This study suggests that even a low corporate tax rate combined with generous depreciation rules does not provide incentives for investors when the inflation rate is high. A case study on Najin–Sonbong FEZ in North Korea delivers a wide range of more crucial economic and political reasons why such a development project can fail, although tax concessions offered there are more favourable than those in China and other Asian nations.     

General Property Reassessment: Relative Tax Impacts on Land and on Structures

A bstract . Many jurisdictions require periodic mass reassessment of real property to bring assessed values closer to market values and to reallocate tax burdens among property types. This paper examines the influence of general reassessment on the tax burden on land relative to that on improvements in Indiana, a state using elected local assessors, statewide mass reassessment on a regular cycle, and assessment of structures at hypothetical reproduction cost. Examination of data over the 1950-51 to 1974-75 period shows that economic growth and development reallocates property tax impact away from land: the share of land in the base declines and the effective rate paid on any given parcel of land declines. Reassessment adjusts these impacts. While reassessment increases the share of improvements in the total base, the readjustment for land is larger. From this analysis, the most recent mass assessment (1968) increased the land to improvement ratio by about 42 percent.     

Are There Tax Arbitrage Opportunities in Private Rental Housing Markets?

Tax arbitrage opportunities in rental housing markets arise when high bracket taxpayers exploit the tax shelter and conversion features of the tax treatment of rental housing and as a consequence offer low bracket taxpayers rental housing at a cost lower than if they purchased the same quantity of housing for owner occupation. A microdata set has been employed to estimate the size of these tax arbitrage opportunities with respect to 1907 properties owned by Australian landlords. The measure of tax arbitrage opportunities is the breakeven tax rate at which the maximum rental rate a potential occupant is prepared to pay before turning to purchased housing is equal to the landlord's reservation rental rate. Potential occupants with marginal tax rates below the breakeven tax rate find that renting has a relative cost advantage over home purchase. When agency costs (the costs incurred in managing landlord-tenant relationships) are included in the tax arbitrage model, our estimates of the breakeven tax rate indicate that home purchase has a relative cost advantage over renting for most potential occupants. Renting is only financially attractive to low tax bracket individuals. This finding is consistent with Australian tenure patterns. However, there are more puzzling results. A majority of landlords belong to tax brackets below the top bracket, landlords in the lowest tax brackets typically make below normal profits, and reservation rental rates at the bottom of the rental housing market are relatively high. Down payment requirements, lock-in effects, and rent clientele groups are put forward as possible explanations for these findings.     

Transaction costs, capital-gains taxes, and housing demand

The paper considers the effect of transaction costs—particularly in the form of capital-gains taxes—on the aggregate demand for owner-occupied housing. The framework is an overlapping-generations model, where consumers can avoid the transaction costs (taxes) by keeping the same house for both periods of life. The first part of the paper analyzes the consumer's choice problem. It distinguishes between costs that are fixed irrespective of the size of the house bought or sold, and costs such as capital-gains taxes that are related to the house value. It is shown that higher transaction costs have lock-in effects, inducing consumers to keep the same house for both periods. Also it is found that under a wide variety of circumstances the amount of housing demanded will increase as the household is being locked in. Finally, the paper looks at the effects on aggregate demand from an increase in capital-gains taxes. It is shown that an increased rate of taxation decreases demand for low tax rates. But for high tax rates, when lock-in effects become important, one generally gets the opposite effect; high tax rates tend to increase housing demand.     

Tax strategies and organisational communication in MNC supply chains: case studies

Communication is a key component of operational efficiency which in turn contributes to a firm’s profitability by reducing costs. In addition taxes are a significant expense for profitable firms. Multiple methods for tax avoidance have been developed by firms and their advisors but the effects on operations are rarely considered. Evidence was found that tax avoidance decisions are made in isolation at the head office and operational monetary and cultural costs are not fully accounted for. Better communication can mitigate these disruptions but it is not a primary concern of central management. Depending on its operational intrusiveness, there is variation in levels of organisational disruption caused by the tax avoidance method implemented. These effects can be far reaching. Careful consideration of organisational costs for each tax avoidance method should be made prior to any being adopted. A framework to help practitioners focus on total costs versus tax savings, is proposed.