历史逻辑与现实理性的税收公平讨论--税制建设的补偿理念

A Discussion of Fair Tax Obligation under Historical Logic and Realistic Rationality:Compensation Idea in the Construction of Tax System

在政治实践中,税收公平的受益和量能两大原则逐渐出现分野。量能原则虽然对税法的制度设计和解释产生重大影响,但是在很多情况下该原则也难以与现实保持一致。笔者以理论分析和历史经验总结的方式探究了政治现实对量能原则的遵循和违背中隐藏的规律和动机,提出西方国家税制公平性实践体现了一种补偿理念,且它是对公平和效率的策略性调和。依据这样的历史逻辑,新冠肺炎疫情或将推动新一轮税制公平性改革。补偿理念也可用于解释我国改革发展实践,但与西方的被动式补偿不同,我国通过主动地、有计划地战略部署,将公平与效率的矛盾化解、统一于社会主义本质要求和根本目标--共同富裕之中。此外,笔者还对国际国内的税制公平性建设进行了分析并提出建议。

In political practice,the two principles of tax equity,i.e.,benefit principle and ability-to-pay principle have gradually diverged,while the latter has attracted significant attention and has a great influence on the system design and interpretation of tax laws.However,in many cases,this principle is not consistent with the reality.By means of theoretical analysis and summary of historical experience,the authors explore the patterns and motives hidden in the observance and violation of the ability-to-pay principle in political reality,and put forward that the tax system construction in western countries reflects a kind of compensation idea,which is a strategic reconciliation between equity and efficiency.Based on this historical logic,the COVID-19 outbreak could push the world into a new round of tax equity reform.The idea of compensation can also be used to explain the practice of China's reform and development.But different from the passive compensation in the west,China resolves the contradiction between equity and efficiency and unifies them in the essential requirement and fundamental goal of socialism—common prosperity through active and planned strategic deployment.In addition,the authors also analyze the construction of international and domestic tax system and provide some suggestions.