数字企业的税收:改革的选择

O. Sokolovska, Sergei Belozyorov
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引用次数: 3

摘要

目前,经济的新型工业化和数字化带来了新的税收挑战,因为新的商业模式的出现,不需要实体存在来进行数字交易。这些挑战通常与税基的侵蚀和公司利润的转移有关,这些公司由于不同的直接税制度而在不同的司法管辖区经营。经合组织国家制定了旨在解决企业避税策略的指导方针(BEPS项目)。现在,欧盟成员国正在积极讨论引入数字税,主要目的是提高数字公司面临的有效所得税税率,以缩小“实体”和数字公司之间的盈利差距。最近的研究表明,与传统企业相比,数字企业所面临的有效所得税率没有系统性差异,因此,关于欧盟数字企业征税的讨论中的基本命题是错误的。我们对数字企业的盈利能力与其有效税收负债之间的关系进行了实证分析,我们排除了日本大型数字企业,因为日本数字税收的特点本质上影响了它们的绩效指标。结果表明,与有效企业税率相比,数字企业的税收费用会对其盈利能力(以税后利润率衡量)产生影响,而数字税是否有影响,取决于其设计,特别是税收优惠和豁免的可用性,以及税率的累进性。
本文章由计算机程序翻译,如有差异,请以英文原文为准。
Taxation of digital corporations: options for reforms
Currently the new industrialization and digitalization of economies leads to the new tax challenges as a result of appearance of new business models, which do not need physical presence to carry out digital transactions. These challenges are generally related to the erosion of tax base and shifting profits by companies, operating in different jurisdictions due to different direct tax regimes. The OECD countries elaborated guidelines (BEPS Project), aimed to address tax avoidance strategies of corporations. Now EU Member States actively discuss the introduction of digital tax, aimed primarily to increase an effective income tax rate faced by digital corporations in order to reduce the gap in profitability between “brick-andmortar” and digital companies. Recent research showed that there is no systematic difference in effective income tax rate faced by digital corporations compared to traditional ones, and therefore, the underlying proposition in the discussion about taxing digital firms in EU is misguided. We provide an empirical analysis of relationship between profitability of digital corporations and their effective tax liabilities. .We exclude big Japanese digital corporations since features of Japanese digital taxation influence essentially on their performance indicators. The results demonstrate that tax expenses of digital corporations, as contrast to effective corporate tax rate, can have an impact of their profitability, measured as after tax profit margin ratio, and whether the digital tax has an impact, depends on its design, notably, availability of tax incentives and exemptions, and the progressivity of tax rate.
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