发达国家房产税征管模式的比较与借鉴

Comparisons and Implications concerning Property Tax Administration Modes in the Developed Countries

鉴于房产税不同于其他税种的特质,发达国家在选择征管模式时都注意保证房产税征收的公平、公正和透明。这些征管目标主要通过房产税评估和征管机构独立设置、必要的争议解决机制、较为复杂的税收优惠政策和政府征税权力的限制等方式去实现。并且,不同的房产税征收模式往往与该国的经济、社会、法律状况相匹配。本文在比较研究中进行了系统的梳理,以期得出有益于中国房产税改革的政策建议。

Due to the particular features of real estate tax than other taxes, many attentions are attached in choosing tax administration modes in the developed countries to ensure the fairness, justice and transparency in the collection of real estate tax. These purposes for tax collection and administration are primarily ful- filled through several approaches, including the inde- pendent institutions between the assessment agencies and the tax collection and administration agencies, the essential disputes resolution mechanisms, the relatively sophisticated tax preferential policies and the power restrictions of tax authorities. Moreover, the distinctive real estate tax administration mode is in accordance with the economic, social and legal conditions of the country. Following these systemic analysis in the comparative research, this paper also provides some policy suggestions for the real estate tax reform in China.