确定增值税税基的基本思路:宽广、完整与准确

A Basic Idea of Determination of the VAT Base:Coverage,Completeness and Accuracy

增值税税基的确定应遵循宽广、完整与准确的思路。现行增值税税基确定上存在因免税规模过大导致税基被侵蚀、因对"应税项目"定性不准导致税基被随意扩大以及部分特殊应税行为的税基确定不够合理等突出问题。本文认为,应按照宽税基的思路,通过免税"瘦身"最大限度地拓展税基;以"价外费用"与应税销售行为之间是否存在内在关联性、是否为销售货物与服务的对价的一部分作为判断是否作为增值税税基的依据,既有效防止税基被侵蚀、肢解,又避免税基确定的随意扩大;还应依公平、合理原则准确确定"视同销售""混合销售""价格明显偏低并无正当理由"等诸特殊情形的增值税税基。

The determination of the VAT base should follow a broad, complete and accurate approach. There are a few of outstanding issues in the determination of the current VAT base, such as tax base being eroded due to excessive tax exemption, tax base being arbitrarily expanded due to qualitative inaccuracy of ＂taxable items＂, and tax base of some special taxable behaviors being determined unreasonably. This paper believes that in accordance with the idea of a broad tax base, the tax base should be maximized through reduction of tax exemption, whether the expense not included in the calculated price should be judged as the VAT base should be based on whether there is an intrinsic relationship between the expense not included in the calculated price and the taxable sales behavior and whether the expense not included in the calculated price is part of the consideration for sales of goods and services or not in order to prevent effectively the tax base from both being eroded and dismembered and being expanded arbitrarily, and also the VAT base for special circumstances, such as deemed sales, mixed sales and obviously low price without justification, should be accurately determined according to the principle of fairness and reasonableness.