中日现代税制结构比较研究

The Comparative Study of Tax Systems between China and Japan

中日现行税制的起点都比较特殊,中国是改革开放,日本是二战失败后美国主导的改革。在此基础上,两国走出了各自独特的税制演进之路。当前,日本税制是以个人所得税为核心的直接税为主的税制结构,分中央税、都道府县税、市町村税3个层次,中央税居于主导地位。中国税制是以增值税、营业税为核心的间接税为主的税制结构,体现了中国是发展中国家这一经济现实。中国的中央税和地方税的划分标准不明晰,省以下没有独立的地方税体系,直接导致共享税过多,已成为下一步税制改革的阻碍。

Both China and Japan have a special starting point in current tax system. Based on China＇s reforming and opening and Japan＇s reforming led by USA after World War II, the two countries have developed its own unique tax system. Today, Japan＇s tax system is mainly the system of direct taxes centered as individual income tax, which consists of national taxes as the leading role, municipal taxes and country taxes. China＇s tax system is mainly the system of indirect taxes centered as value-added tax and sales tax. This reflects the fact that China is a developing country. There is no clear difference between the national and municipal taxes, and there is no independent system of municipal taxes below provincial level. These led to excessive share taxes and became a block of tax reform.