跨境B2C电子商务税收征管的难题与破解——基于微观、中观和宏观税收公平的思考

跨境B2C电子商务的快速发展及其虚拟性和无国界性对税收征管带来了挑战，当前我国的跨境B2C电子商务税收征管日益规范化，但仍面临课税要素界定难的实体性困境和征管流程实施难的程序性困境。在跨境B2C电子商务交易模式下，税收公平原则除了要求个体意义上纳税人间的公平和整体意义上国家与纳税人间的公平外，也强调国家间的公平。跨境B2C电子商务的税收征管，应着力彰显税收公平原则以平衡各方利益，完善和细化税收征管体系以助推征管规范化，并创新国际税收合作方式和内容、加强税收情报交流以实现国际税收协作与共赢。

Difficulties and Solution to Cross-border B2C E-commerce Tax Collection and Management under the Perspective of Tax Fairness

The rapid development of cross-border B2C e-commerce and its virtual character and its property of non-national-boundary bring the challenge to its collection and management. Presently, the tax collection and management of China for cross-border B2C e-commerce is more and more standardized but still faces the practical difficulty in tax collection factor definition and procedural difficulty in tax collection procedure implementation. Under cross-border B2C e-commerce transaction mode, the principle of fairness of the tax collection not only requires the fairness between tax payers and the fairness between a government and an individual tax payer but also highlights the fairness between different countries. Tax management of cross-border B2C e-commerce should pay attention to fairness principle to balance the interests of each party, perfect and make detailed tax collection management system to standardize tax collection, innovate cooperation mode and contents for international tax collection, and enhance tax intelligence communication to realize the cooperation and double-win of international tax collection.