企业集团内部市场的避税效应——以A集团为例

Tax Avoidance Effect in Internal Market of Enterprise Groups:Evidence from A Group

文章以A集团为例,依托避税理论、企业集团理论,分析企业集团内部市场的避税效应。研究发现:A集团高度集中的股权结构有利于控制人配置资源、实施内部市场利润转移交易; A集团的子公司分布在福建、重庆、上海等国内各个地区和美国、俄罗斯等海外地区,享受地区和行业多种税收优惠政策,承担原材料、半成品和产成品生产、贸易等多种职能,集团内部形成存在地区税率差异的内部市场;收入和利润主要向低税率的子公司和分支机构转移; A集团的实际税率低于同行业实际税率均值。

This paper takes A Group as an example,relying on tax avoidance theory and enterprise group theory,to analyze how to realize tax avoidance in the internal market of enterprise group. The paper finds that the highly centralized ownership structure of A Group is conducive to the controllers’ allocation of resources to implement internal market profits transfer transactions. A Group’s subsidiaries are located in various regions of China,such as Fujian,Chongqing,Shanghai,and overseas such as the United States and Russia. These subsidiaries enjoy a variety of regional and industrial preferential tax policies and undertake various functions such as raw materials production,semi-finished products and finished products production,trade and so on. Various preferential tax policies form an internal market with different regional tax rates within the group. Moreover,income and profits are mainly transferred to subsidiaries and branches with low tax rates. Thus,the actual tax rate of A Group is lower than the average level of the industry.