With the rapid development of the digital economy, the continuous improvement of technical means, and the renewal of social consumption concepts and methods, emerging formats such as webcasting, live streaming, and digital marketing have emerged in society.
The "Opinions on Supporting the Healthy Development of New Business Formats and New Models, Activating the Consumer Market and Driving Employment Expansion" issued by 13 departments including the National Development and Reform Commission proposed to support the development of 15 new business formats and new models, including online education, Internet medical care, digital transformation of traditional enterprises, "Virtual" industrial parks and industrial clusters, "unmanned economy", shared production, etc.
The new economy has brought new momentum, and new growth points of tax revenue have become increasingly prominent.
Recently, 31 provinces, autonomous regions and municipalities have intensively released local fiscal and tax accounts. In 2021, the fiscal revenue of each province will show a recovery growth, and new business formats and new models will become new growth points for taxation in many places.
Judging from the data released by the General Office of the State Administration of Taxation, in addition to the retail, real estate and construction industries, a considerable number of newly established tax-related market players have entered the modern service industry and emerging industries.
At the same time, since some new economic formats are still uncertain at the legal level, a series of new problems and challenges in taxation have also arisen.
In particular, the frequent occurrence of tax evasion by practitioners in emerging business formats directly affects the order and fairness of income distribution.
How to strengthen the tax supervision of new business practitioners?
How should the fiscal and taxation system adapt to the transformation of old and new kinetic energy and new and old patterns in the process of economic development?
How can the tax system reform more effectively play the adjustment function of secondary distribution and promote social fairness and justice and common prosperity for all people?
This is a problem that China urgently needs to solve.
One: Traffic economy: there are many "fugitives" in the new favorite tax
Banyue Talk Reporter Julie Lim Guangyao Wu Yanxia Pan Ye Liu Hongyu Yin Peng
Since last year, there have been frequent tax-related cases in the Internet celebrity economy, which has aroused strong public attention to the tax evasion problem of high-income groups such as Internet celebrity anchors.
The tax authorities in many places have continued to strengthen the tax supervision of practitioners in the online live broadcast industry, and many tax problems of online live broadcast practitioners have surfaced.
The amount of tax evasion by Internet celebrity anchors is huge, and tax avoidance has become an unspoken rule in the industry
Xie Jun is a full-time video blogger and "Waist Net Red".
Advertising, as Xie Jun's source of income, mainly comes from two channels: one is to contact and sign contracts with the brand through the short video platform's own advertising platform, and the short video platform acts as a "middleman" to meet the needs of both parties, and the advertisements that need to be shot are " The task” is distributed to the corresponding bloggers, and personal income tax is deducted during the settlement period; the second is to directly sign a contract with the brand. Generally speaking, customers will require personal income tax to be deducted from the blogger’s income, and the account is the after-tax income.
"I remember one time I signed an advertisement with a total price of 50,000 yuan, and I paid several thousand yuan in personal income tax. It was very distressing." Xie Jun said.
Xie Jun revealed that some big video bloggers and anchors have established companies to calculate such income as operating income, and then avoid taxes. It is an unspoken rule that many people in the industry know.
"Many practitioners now think that this is a bowl of 'youth rice' and 'earning quick money'. The update and iteration cycle of Internet celebrities is very fast, and many people are afraid that they will be out of breath one day, so they work hard and make money. Hoping to make as much money as possible in a short enough period of time to 'retire' soon."
At the end of 2021, the tax evasion case of well-known Internet anchor Huang Wei (net name "Weiya") has become the focus of heated discussions.
After verification by the tax department, between 2019 and 2020, he evaded tax of 643 million yuan by concealing personal income and making false declarations of the nature of business conversion income.
In accordance with relevant laws and regulations, the taxation department pursued the payment of taxes, imposed a late fee and imposed fines on Weiya, totaling 1.341 billion yuan.
The incident caused an uproar.
Internet celebrities "Sydney" and Lin Shanshan were also suspected of tax evasion, and were charged with late fees of 65.5531 million yuan and 27.6725 million yuan respectively.
On February 22, 2022, the taxation department of Guangzhou City, Guangdong Province punished online anchor Pingrong (net name: Donkey Sister Pingrong) for tax evasion and other acts in accordance with the law. times the fine, totaling 62.003 million yuan.
fluke mentality
Wang Dawei (pseudonym) from Guangxi We Media is an account operator with millions of fans. Over the years, he has led the company's team to produce and update short videos, bring goods through live broadcasts, and conscientiously build a personal social brand.
In his view, the phenomenon of Internet celebrity tax evasion has been exposed one after another, reflecting two problems: one is that some anchors and Internet celebrities have high and complex incomes, and the definition of income is ambiguous; the other is that these emerging industries are engaged in business entities. A large number of them have emerged and are showing a savage growth trend. The tax authorities have not been in place in the supervision of some entities and platforms in a timely manner, and there is a lack of normalized and effective communication methods between the two.
"Some companies and streamers have little awareness of tax laws, and many people have a fluke mentality, not only do not pay attention to the issue of honest tax returns, but also change the nature of income to pay less taxes, just thinking about how much their wealth has increased, We did not take social responsibility and take the lead in giving back to our hearts." Wang Dawei said.
An operator of a media company revealed that in addition to contracting anchors, the company also provides offline media-related services. Since online anchors are relatively flexible, labor contracts may not be perfect, and anchors are highly mobile. Strictly regulating the number of streamers a company hires is not easy.
Therefore, in terms of tax payment, some media companies have not paid the full amount of tax on the income of online contracted anchors, and the contracted anchors also have a fluke mentality.
Enhancing awe in regulation
The online live broadcast industry is not a blind spot for tax supervision. It is necessary to promote industry norms and development through reform and innovation, and solve the regulatory problems of the online live broadcast industry.
"The number of online live broadcasters is increasing. To purify the tax chaos in the cyberspace, we must promote reform and innovation in many ways, including Internet presence and increasing tax law publicity, so as to patch loopholes and reduce the possibility of tax evasion and evasion by practitioners." Wang Dawei believes that, Once it is included in the scope of supervision, the awe of the relevant practitioners will be enhanced, and naturally they will not dare to evade tax.
Xu Zhengzhong, a professor at the Economics Department of the Central Party School (National School of Administration), said that the regulation and supervision of taxation for the flow economy is an important manifestation of social fairness. In the future, the implementation of relevant laws and policies to promote social fairness will become stronger and more accurate.
Two: How difficult is it to tax the platform economy
Ban Yue Talk reporter Liu Hongyu Pan Yeyin Peng Lin Guangyao Zhu Lili Wu Yanxia
"The platform economy is actually changing China's microeconomic structure," said Du Chuang, director and researcher of the Microeconomics Research Office of the Institute of Economics of the Chinese Academy of Social Sciences.
With the rapid development of the platform economy, new business models and economic formats continue to emerge, and the traditional industry classification standards are increasingly inappropriate.
At the same time, the platform economy transforms some tangible goods and services into digital forms for sale, making it difficult to distinguish between goods, services, and concessions, and tax issues are more complicated.
Platform economy tax issues are complex
How to accurately define an enterprise's industry ownership and applicable tax rate, and how to judge whether an enterprise can apply the difference tax policy, etc., has become increasingly uncertain, which often leads to different opinions on the same business between tax authorities and enterprises.
First, the tax collection and management concept of the platform economy is not yet perfect.
On the one hand, some local governments regard the platform economy as a new economic growth point, and will strongly welcome the platform companies that come to settle down without distinguishing the authenticity.
The tax authorities have optimized the tax procedures for platform economic market entities, but lacked corresponding monitoring and auditing of platform tax sources.
Some platform companies fished in troubled waters and launched false businesses, resulting in platform explosions and frequent issuance of false VAT invoices.
On the other hand, due to the influence of traditional experience, tax authorities in some regions have insufficient understanding of the platform economy, a new economy and new business format that integrates technological innovation, business model innovation, service innovation, and institutional innovation.
Under the circumstance that the methods and means of tax collection and management accumulated over a long period of time are difficult to apply to the platform economy, it is difficult for tax personnel to change the concept of tax collection and management in a timely manner and apply big data and other information technology means to conduct tax collection and management, resulting in some tax authorities. No matter whether it is true or false, it is against the desire of the local government to develop urgently.
Obviously, a loose management method that ignores risk prevention and a “one size fits all” management method are not desirable.
In addition, the tax burdens of different taxpayers in the platform economy are uneven.
In the process of sustainable development of the platform economy, a large number of freelancers (natural persons) become platform service providers, and the platform and the operators on the platform jointly create value.
Therefore, whether the market entities participating in the platform economy can enjoy the same tax treatment without discrimination is very important to the standard and healthy development of the platform economy.
The post-90s Xiao Gao is a full-time writer.
Her monthly guaranteed manuscript fee for writing novels is roughly 2,000 to 3,000 yuan, and her income from the adaptation of comic scripts is about 2,000 yuan. These manuscript fees are paid by the platform after tax deduction.
There are many writers on some platforms, and the remuneration is high or low. It is difficult to supervise the platform’s independent tax deduction.
Leng Jian (pseudonym) is an online script killing app host. There are more than a dozen script killing hosts who joined the platform together with him. Everyone competes according to how much they live and how popular they are, and their income varies.
"Of course, the platform has to take away some of the money. The smooth operation of a good book depends not only on the moderator, but also on the joint efforts of everyone behind the writing, testing, beautification, and maintenance."
The tax collection and management mechanism of the platform economy needs to be improved urgently
At present, the use of blockchain technology by tax authorities is not extensive enough, and it is difficult to timely and accurately grasp the tax-related information and data related to the market entities of the platform economy, and it is difficult to achieve in-depth supervision of the platform economy.
On the one hand, the platform economy itself has the characteristics of strong transaction concealment and difficult to track the transaction process, which has brought great challenges to tax collection and management; Difficulty in the supervision of the agency.
Some platform companies do not have the support of information systems, but simply transfer offline business to the Internet "manually", or technically import relevant information from other platforms.
Some platform companies do not have substantive commercial transactions, and the business contract flow, information flow, capital flow, logistics, ticket flow and other information cannot be matched one by one, and the authenticity of the business cannot stand the test.
Because natural persons are temporarily unable to apply for the issuance of special VAT invoices, some platform companies are unable to obtain VAT input invoices, adopt large amounts of cash transactions, search for invoices outside the platform, issue invoices to offset input items, or require tax authorities to verify and collect income tax.
In order to obtain more financial subsidies, some platform companies have artificially created false transactions, falsely issued VAT invoices, and committed illegal and criminal acts.
In addition, the formulation of relevant tax regulations and policies for the platform economy lags behind.
Up to now, my country's current tax laws, regulations and policy documents have a large gap in the regulations on the tax collection and management of the platform economy, which increases the difficulty of the implementation of tax authorities at all levels and the realization of tax compliance goals for the platform economy, which is not conducive to the long-term platform economy. stable development.
Strengthen the management of VAT invoices on the platform
Standardize the issuance of economic value-added tax invoices on the platform.
From the tax policy level and technical level, it will completely solve the problems of insufficient input tax credit for platform enterprises, difficulty in obtaining legal tax deduction certificates, and the issue of VAT invoices for operators on the platform, effectively reducing the actual tax burden of platform economic market players.
Accurately divide business types and standardize the behavior of invoicing.
For the business that earns the price difference by means of resale of labor services, when a platform enterprise purchases services from an operator on the platform, it can apply to the tax authority on its behalf, and issue a VAT invoice to the enterprise. The buyer is the platform enterprise and the seller is the operator on the platform. By.
For matching business, platform companies provide brokerage agency services. Platform companies can apply to tax authorities for operators on the platform, and issue VAT invoices to labor buyers. The buyers are the buyers of labor services, and the sellers are operators on the platform. provider.
For the outsourced labor service business (not on the platform) of the platform company for resale, the labor service provider will issue an invoice by itself.
Operators on platforms of different levels are allowed to reasonably enjoy tax incentives to meet their diverse tax needs.
For operators on the platform with monthly sales of less than 150,000 yuan, they may be allowed to enjoy a certain degree of inclusive tax reduction and exemption policy as appropriate, and are exempt from value-added tax (except for the issuance of special VAT invoices).
For operators on the platform with monthly sales of 150,000 yuan or quarterly sales of more than 450,000 yuan, because their sales have exceeded the current tax-free standard, they can entrust the platform enterprises to apply to the tax authorities to obtain invoices on their behalf.
For operators on the platform that meet the standard of general taxpayers, they need to declare and receive invoices by themselves.
Accurate guidance platform enterprises, strengthen the management of value-added tax invoices.
Ensure the reasonable number of invoices and page quotas required for the normal operation of compliance platform companies, and support compliance platform companies to use internal vouchers and external vouchers to list costs and expenses.
For expenditure items that are taxable items of value-added tax, it is recommended to use the value-added tax invoice as the pre-tax deduction certificate for enterprise income tax; for small and sporadic businesses that provide less than 500 yuan, such as registered members, the internal certificate can be used as the pre-tax enterprise income tax. Legal evidence of deduction.
The third: the sharing economy challenge "control tax by ticket"
Ban Yue Talk reporter Lin Guangyao Zhu Lili Wu Yanxia Yin Peng Liu Hongyu Pan Ye
According to the "China Sharing Economy Development Report (2022)" released by the State Information Center on February 22, in 2021, the transaction scale of my country's sharing economy market will be about 3,688.1 billion yuan, a year-on-year increase of about 9.2%.
The report believes that in 2021, the competition among sharing economy platform companies will become more intense, some industries will enter a new period of integration, and a new round of "shuffle tide" will appear in some fields. Platform companies that have accumulated a certain scale of users are diversifying Expansion of scenarios and diversified business models.
The rapid growth of the sharing economy and the rapid changes in the market structure have brought new challenges to the current tax collection and management system.
A new round of "shuffle wave" appears in the sharing economy
"July 2021 is an important turning point in the change of the market structure in the shared travel field." Sun Baowen, Dean of the China Internet Economic Research Institute of Central University of Finance and Economics, said that various online car-hailing platforms have launched new market strategies, and a large number of second-tier online car-hailing platforms have been launched. Strengthen promotion in various ways, invest a lot of capital subsidies on both drivers and passengers, and accelerate the entry into different cities.
In the field of knowledge sharing, audio content products have attracted more and more public attention, and the "ear economy" based on sound has developed rapidly, and its huge potential has attracted head platform companies to enter the market.
In 2021, ByteDance’s Tomato Novel will launch “Tomato Listening”, WeChat will launch “WeChat Listening”, and Kuaishou will launch the podcast app “Kayaks”.
These new entrants have rich content and traffic resources, further intensifying market competition in this field.
In April 2021, the head of the shared power bank, Monster Charge, was launched, and Jiedian and Soudian were officially merged, resulting in a new adjustment in the market structure.
The competition in the shared power bank field will continue to intensify, the advantages of leading companies will be further strengthened, the brand effect will become more prominent, and the survival and development of tail brands will face greater pressure.
Searching for the keyword "shared study room" in Dianping App, there are nearly 100 results in Hangzhou alone.
Investor Hu Jiameng believes that shared study rooms provide urbanites with space for personal growth.
"It's too difficult to find a quiet place to read and think, so I came up with the idea of making a shared space focused on personal growth. We provide new customer experience cards, as well as medium and long-term membership cards, our goal It is about half a year after opening to achieve an overall balance of payments.”
Hu Jiameng is optimistic about the operation prospects of the shared study room.
"The sharing economy involving personal growth and private space has been a trend in recent years, and the products and services on the market are gradually being updated. We have confidence in this segment, as well as our carefully crafted shared self-study program. Space has confidence.”
In response to various problems in the development of the sharing economy, the construction of relevant legal systems in my country has continued to advance, the governance system has been continuously improved, and the market order of the sharing economy has been further standardized.
Relevant departments will also take more refined governance measures, especially taxation, to promote the healthy and standardized development of the industry in response to the development characteristics and existing problems of new business formats such as online car-hailing and live e-commerce.
Sharing economy tax governance is difficult
First, the tax system related to sharing transactions is not perfect.
Shared transactions are generally conducted online, and online transactions break geographical restrictions and blur the scope of tax jurisdiction to a certain extent.
Under the traditional taxation model, the taxpayer generally conducts transactions in a fixed place, and the VAT and other taxes generated are registered with the tax authority at the place where the transaction is conducted, and the taxpayer then bears the tax liability at the place of the transaction.
Since there is no fixed place for shared transactions, all transactions can be carried out on the virtual network, and the difficulty of tax collection and management is correspondingly high.
In the sharing economy, it is difficult to determine whether certain transactions should be taxed, and the collection of personal income tax has also had a significant impact.
my country's personal income tax implements a tax system that combines comprehensive and classification. Under the traditional collection method, when collecting taxes, it is necessary to determine the source and nature of the taxpayer's income.
However, in the sharing economy, the forms of personal remuneration are diverse, and the nature of income cannot be truly and effectively determined.
For example, in the sharing economy, "online appointments", from the nature of their work, may form either an employment relationship, a labor relationship or a cooperative relationship with the platform.
If it is not possible to precisely define the nature of its remuneration, it is also impossible to determine under what tax system it will be taxed.
Second, it is difficult to obtain information on taxpayers.
Tax governance first needs to clarify the governance object, that is, the taxpayer, but it is difficult to determine the taxpayer in the sharing economy.
Tax authorities do not have a high degree of participation in sharing economic transaction activities, and cannot obtain real, effective and comprehensive transaction information. The asymmetry of information makes it impossible for tax authorities to obtain complete information on taxpayers.
Moreover, the entry threshold for sharing platforms is low, and many individual practitioners have not conducted relevant tax registrations at all. When relevant transactions occur, it is difficult for tax authorities to find traders.
The trading activities of the sharing platform have virtual characteristics, the income of the operators is basically dynamic, and the tax authority cannot determine the taxpayer based on the virtual trading activities and dynamic income.
Again, the challenge of "controlling taxes by ticket".
"Tax control by ticket" is a tax collection method commonly used in the real industry, but "tax control by ticket" is difficult to apply in the sharing economy.
"Invoice control tax" must specify the taxpayer. If the taxpayer is attributed to the consumer, the consumer should obtain the full payment invoice.
However, in the actual transaction process, the direct transaction object of the consumer is the third-party sharing economy platform. At the same time, the supplier does not have an invoicing link, so it naturally evades the tax liability.
"Tax control by ticket" uses capital flow, invoice flow, and goods flow to verify the authenticity of invoices, and only when the "three streams" are consistent can the authenticity of invoices be proven.
In terms of capital flow, under the sharing economy, capital payment channels are various and all in the form of data, and it is difficult for tax authorities to effectively judge whether the capital flow is consistent with the actual situation by using existing technical means.
In terms of invoice flow, the online transaction information of enterprises and individuals is mainly presented in electronic data. The comparison method of invoices is only data verification, and real invoices (paper invoices) cannot be identified, which leads to the virtualization of both parties in the invoice business. Billing data cannot confirm the authenticity of the taxpayer's business.
In terms of cargo flow, the purchase and sale of goods by enterprises or individuals has the characteristics of high flow and high turnover. In addition, the logistics industry is relatively complicated. Most enterprises adopt the method of affiliated operation with individual practitioners, and logistics and transportation operators who do not issue invoices or do not need invoices can be seen everywhere. , which also increases the difficulty for tax authorities to verify the authenticity of the goods.
Finally, risk identification is difficult.
The basic information of tax governance is mainly obtained through tax registration, tax declaration, etc., and is saved by manual entry.
However, in the sharing economy, the amount of data information is huge and difficult to obtain manually, and it is difficult to distinguish between valid data and invalid data, which seriously affects the risk identification in the process of tax risk management.
The sharing economy presents the characteristics of a long-tail economy and a collaborative economy, and the driving factors for development are mainly data.
Under this economic model, the traditional risk identification model is difficult to effectively identify the tax risks of the sharing economy, which increases the difficulty of tax administration by tax authorities.
Improve the sharing economy tax governance system
- Improve tax laws and regulations.
It is necessary to formulate clear legal provisions on the industry ownership and income nature of the sharing economy, clarify the controversial business activities in the form of positive enumeration, accurately define the taxpayers, revise the identification standards for the place where digital economic activities occur, and redefine the territorial management rules. , simplify the value-added tax rates for different goods and services, expand the taxation scope of comprehensive personal income tax, and solve tax disputes and unfair tax burdens caused by unclear classification of tax items and income.
At the same time, a unified identification standard should be formulated to give full play to the media function of the third-party sharing economy platform, so that it can undertake the responsibility of connecting taxation, market supervision and other departments with the sharing economy entities.
It is also necessary to improve the entrusted collection mechanism of third-party sharing economy platforms, standardize the tax governance order, and clarify the withholding and payment obligations of e-commerce platforms and third-party payment platforms.
- Improve the credit management and tax system.
The so-called credit management tax system is to establish a new credit governance mechanism in which "credit" runs through the entire life cycle of transaction entities and connects all links before, during and after the event.
In the aspect of innovating the credit management of the prior link, it is necessary to actively carry out law-abiding integrity education, establish and improve the credit commitment system, encourage taxpayers to take the initiative to make credit commitments, and improve tax compliance.
In terms of strengthening the credit management in the middle of the matter, it is necessary to comprehensively establish taxpayer credit records, improve the comprehensive tax credit evaluation system, promote the dynamic management mechanism of credit classification and classification, and vigorously improve the quality and efficiency of credit supervision.
In terms of improving credit management in the post-event link, it is necessary to promote cooperation between departments, improve the mechanism for identifying the targets of joint punishment for dishonesty, and carry out joint punishment for dishonesty in depth; with the support of data and platforms, it is necessary to fully disclose information on breach of contract and illegality, and provide a “portrait” for the credit situation of specific taxpayers. ”, to fully implement the credit mechanism of incentives for keeping promises and punishments for dishonesty.
——Establish a collaborative and co-governance mechanism.
It is necessary to establish a tax source control and sharing mechanism, actively communicate and coordinate with the financial department, formulate an implementation plan for regional comprehensive tax governance and grid management of financial resources, and consolidate the main responsibility and supervision responsibility of taxation.
It is necessary to establish a joint disciplinary management agency, set up a joint office mechanism with financial, real estate management, public security, finance and other departments, build a joint credit investigation system, strengthen the exchange of untrustworthy tax payment information, and regularly announce to the public the tax evasion and fraudulent behavior of taxpayers.
It is necessary to formulate the tax department's own platform governance rules based on the actual situation, embed the tax collection and management system and governance needs, promote the integration of finance, taxation, and industry, reduce the space for non-compliance with tax laws, and reduce the loss of tax revenue.
Fourth: Taxation of data assets has become a worldwide problem
Ban Yue Talks Reporter Yin Peng Pan Ye Liu Hongyu
my country's tax legal system is based on the traditional industrial economy, and it does not take into account the characteristics of data assets and their development trends, which leads to a significant tax gap between data assets and traditional production factors, resulting in unfair tax burden Phenomenon.
As the scale of data asset transactions continues to expand, the loss of data asset tax revenue is also more serious.
Therefore, as a data asset that can generate value and can bring income and profit, whether it should be taxed, at what stage, and how to determine the tax base and tax rate have attracted great attention from the tax theory and practice circles.
There are three difficulties in the taxation of data asset transactions in my country
First, it is difficult to determine the tax base of data assets.
At present, most data asset transactions occur between affiliated companies, which are affiliated transactions.
However, the prices of data assets related transactions of many companies are often low, or even do not charge fees, or the prices are high to achieve tax avoidance, making it difficult to determine the tax base of data assets.
When income tax is levied on data assets, it is often difficult to determine the expenses corresponding to the formation of the data assets, and it is often difficult or impossible to deduct the expenses, or the deduction is excessive. Therefore, it is difficult to determine the taxable income of the data assets.
Not only that, there are limitations in the method of assessing and determining the tax base of data assets, whether it is in the collection of value-added tax or in the collection of income tax.
由于数据资产是动态的，不但其时效性较难估计，其使用期限也不易确定，进而导致其未来收益期限长短较难确定。尽管我国已出现诸如贵阳大数据交易所、上海数据交易中心等数据交易机构，但受限于交易平台的不成熟，无法提供大量、全面的交易参考数据，数据资产交易频率较低、种类较少、规模不大，尚不足以形成公允的市场价格。
第二，数据资产的税率确定难。
数据资产很难找到进项税额进行抵扣。如何设计合理的数据资产课税税率，以更好促进数据资产和交易发展，是目前数据资产交易课税中的一大难点。
第三，数据资产课税征管难。
作为可以生产、加工、流通和利用的数据资产具有通用性、虚拟性、外部性、交易性和价值性等特点。数据资产交易往往与其他资产交易混合交织进行，难以明确区分。纳税人在一项交易中同时涉及数据资产和其他资产，其交易行为应当如何缴纳税款，是否应分别核算其应税收入，分别核算时如何准确计量数据资产的交易价格和经济效益，数据资产的成本及其价值增值、所得数额该如何计量等，这些都对数据资产课税的税收征管提出了挑战。
数字经济下新税制尝试
国家税务总局税务干部学院高级研究员姜跃生指出，如何应对数字经济对国际税收规则的挑战，已成为国际社会关注的热点问题，其他国家也在不断进行数字经济下的新税制尝试。
新加坡实行“聊天报税”，纳税人可通过与机器人对话实现便捷报税；智利使用电子文档开展税务审计，生成预警信息；阿联酋运用大数据快速退税……
中国已经明确了“十四五”时期智慧税务建设蓝图，将以发票电子化改革为突破口，以税收大数据为驱动力，全面推进税收征管数字化升级和智能化改造，积极推行“非接触式”办税。
In response to large multinational digital companies shifting profits and eroding the tax base, and in order to protect local small and medium-sized enterprises, some countries have imposed a digital service tax (DST) on Internet companies.
France levies a 3% digital service tax on services that provide digital interface services, targeted advertising services, and services that transmit user data for advertising purposes, and the United Kingdom levies a 2% digital service tax on search engine services, social media services, and online marketplace advertising services. Italy, Hungary, Austria and other countries also levy digital service tax ranging from 3% to 7.5% on online advertising services.
The current digital service tax is still "rough", far from being rigorous and standardized in tax laws.
For example, France calls the digital service tax "GAFA tax".
The digital service tax only provides a general framework: Internet companies are taxpayers, Internet service income is taxed, proportional tax rates are adopted, thresholds are specified, and so on.
The epoch-making significance of the digital service tax is that it marks the beginning of the new tax system of the digital economy in the knowledge age, and it brings a new dawn of the world tax system reform.
Since the digital economy deviates from or even deviates from the three profit distribution principles of "physical existence", "separate entity" and "arm's length principle" based on the current international tax rules, we can only make every effort to promote the use of intangible taxable existence, global single entity, appropriate New tax linkage and profit split method featuring formula distribution.
If an international consensus is reached, it will usher in a drastic change in international taxation rules unseen in a century, and will have a profound impact on cross-border investment, international economic and trade patterns and even the world economy.
Jiang Yuesheng said that China is not only a major capital importer and exporter, but also the world's largest trading country in terms of import and export volume. The new international digital taxation scheme focuses on the distribution of profits generated by cross-border activities among countries, which involves China's core interests and must be given great attention. , come up with China's attitude and position and countermeasures.
Source: "Ban Yue Tan Internal Edition" Issue 4, 2022
Original title "New business formats force tax reform"