税收稽查体制改革与企业集团资本结构调整

Tax Inspection System Reform and Group Capital Structure Adjustment

企业集团是公司的重要组织形式,也是我国税收的重要来源,但集团公司通过内部股权市场进行利润转移和避税问题日趋严重,应受格外重视。本文利用手工建立的集团子母公司关联网络数据库,借助税收稽查体制改革的自然实验,探究了稽查对集团网络内债务转移活动的影响。本文发现,税收稽查体制改革在促进当地企业纳税遵从的基础上可能会激发集团内部的避税动机,具体而言:(1)当母公司所在地实施改革后,集团会将债务由未受影响的子公司转移至母公司,以获得利息抵扣所带来的“税盾”效应,这会导致母公司债务提升,子公司债务降低;(2)税收稽查促使集团通过关联购销和利息收付将利润由母公司转移至未受影响的子公司,后者采取真实活动盈余管理的手段降低利润水平,达到避税目的;(3)集团债务转移活动削减税收稽查真实政策效应的24.78%左右。在全面推进税收治理现代化的背景下,本文的发现对于理解集团公司避税机制及税收政策有效性具有重要意义。

The report to the 20th National Congress of the Communist Party of China states that we will optimize the tax structure and enhance the roles of taxation,social security,and transfer payments in regulating income distribution.Nowadays,taxes not only are viewed as a policy tool,but serve as an important pillar of a socialist market economic system.Tax collection and management is an important guarantee of a country's fiscal revenue,and the efficiency of tax collection and management serves as a crucial indicator of a country's fiscal capacity.Specifically,the taxes of group companies should be given significant attention to ensure effective risk prevention,control,and supervision.This is because the supervision of tax avoidance by group companies poses greater challenges and encompasses a broader scope.The improved tax governance system in China has not yet effectively curbed the collective and covert methods of tax avoidance employed by Chinese companies.In 2017,the spot check of tax sources showed that the average tax amount to be made up checked at the group level was CNY 1.165 billion,a year-on-year increase of 80.39%.Therefore,a better understanding of the characteristics,methods,and size of tax avoidance by group companies can ensure that the taxes are fully levied in time and further improve the critical requirements of the tax collection and management system.Group companies have various ways to avoid taxes,and the problems of profit shifting and tax avoidance by group companies through the internal equity market are becoming increasingly serious,which require special attention.This paper uses the manually established affiliated network database of the subsidiary and parent companies,and the natural experiment of the tax inspection system reform to explore the impact of tax inspection on the debt-shifting activities of group companies based on the motivation of tax avoidance.This paper finds that although the reform achieves significant results in promoting companies'tax compliance,it stimulates tax avoidance motivation.Specifically,firstly,after the reform was implemented in the parent companies'location,the group companies would transfer the debt from the unaffected subsidiaries to the parent companies to obtain the"tax shield"effect brought by the interest deduction,which increased the parent companies'debt and decreased the subsidiaries'debt,while the overall debt level of the groups remained unchanged.Secondly,the tax inspection urged the group companies to transfer profits from the parent companies to the unaffected subsidiaries through related-party purchase and sale,and interest collection and payment.The latter adopted the means of real activity earnings management to reduce the profit level and achieve the purpose of tax avoidance.Thirdly,the groups'debt-shifting activities could reduce about 24.78%of the real policy effect of tax inspection.The main contributions are as follows.First,the existing literature mainly focuses on the channels and motivations of multinationals'tax avoidance,whereas we investigate the profit shifting and tax avoidance of Chinese companies from the standpoint of group companies.Second,the previous literature related to Chinese companies emphasizes the tax avoidance and governance of an individual company,which tends to underestimate the size of tax avoidance but overstate the effectiveness of tax supervision policies.In contrast,our paper incorporates the tax avoidance strategies of the group companies in a general equilibrium framework.Third,there is little literature studying profit shifting and tax avoidance by group companies through the internal equity market.Hence,we base our analysis on the channel of thin capitalization and discuss its impacts on the direction,ways,and size of debt shifting in depth.Our research provides several policy implications.(1)The tax collection and management agencies should lay greater stress on the assessment of the authenticity and effectiveness of tax policies.When formulating and implementing tax policies,the agencies should conduct a comprehensive analysis of the policy heterogeneity and corporate strategic responses to ensure the effectiveness of these policies.(2)The management of anti-tax avoidance in a country should be strengthened via different channels to ensure the more regulated tax payment actions of companies.(3)It is significant to promote the informatization and integration of tax management and cut off the profit shifting and tax avoidance channels in the group's network.