基于反避税要求的税制改革国际视野

Tax Reform Based on Anti-tax Avoidance from the International Perspective

税基侵蚀和利润转移是经济国际化、全球化的必然产物,并随着新技术的发展与国际经济形势下行压力的加大而更加复杂与严峻。多年来,国际社会已采取多种措施积极应对,但由于税基设定属于一国独立自主行使经济主权的范围,因而通过采用统一的国际税收方略来解决各国税收利益失衡的做法存在明显的局限性。在我国,尽管近几年来已取得较为显著的反避税成效,但随着后金融危机时代下跨国企业日益激进的税收筹划和精心设计的避税方案的运用,频繁的税基侵蚀与利润转移行为已给税收征管带来了严峻挑战。在已启动的新一轮税制改革中,应注意以国际视野推进税制改革与征管改革。

The Base Erosion and Profit Shifting, an inevitable product of economic internationalization and globalization, becomes more complex and severe with the development of new techniques and the increasing downward pressure of international economy. Over the years, in response to it, the international community has taken various measures, but there are obvious limitations in the practice to address the tax benefit imbalance among the countries by adopting a unified international strategy because tax base setting belongs to the range of the economic sovereignty a country exerts independently. Frequent tax base erosion and profit-shifting behaviors have posed a serious challenge to the tax collection and management in China with the use of increasingly aggressive tax planning and well-designed tax scheme by the multinationals in the post-crisis era although China has made more significant effects in anti-tax avoidance in recent years. The reform of tax system and tax collection and management should be promoted from an international perspective in the newly-launched round of tax reform.