美日中地方税制比较

1、美 日 中地方税制比较( Comparison of local tax system inAmerica and Japan )Comparison of local tax system in America and JapanComparison of Local Taxation in the United States and Japan 2008-12-20 15:15:34Market economy demands legalization and standardization, requires fair competition conditions, requires b

2、reaking regional division, forming a unified national market, and strengthening the macro-control of the central government. These internal requirements of the market economy can only be realized through the implementation of the tax sharing system. The essence and main content of the tax sharing sy

3、stem is to establish two sets of independent tax system in the central and local governments. Therefore, all countries which implement the tax sharing system attach great importance to the construction of the two sets of central and local tax systems, and have accumulated someexperience in this rega

4、rd, and there is a certain law to follow. Our country from 94 years in the country to implement a unified tax system in the financial management system, the reform of the tax system as the core, will further promote the reform of the tax system and the reform of government institutions, promote the

5、reform of the budget management system, promote enterprise reform. Although 94 years of tax reform, China established a socialist market economyand local tax system, and achieved preliminary results, but because of the immaturity of theory and practice of the lack of experience, Chinas local tax sys

6、tem is not scientific and reasonable, in practice need to continue improvement,continuous improvement, and the market-oriented reform, the objective requirements of Chinas tax system to movecloser to the international practice. The successful experience of the design and reform of the local tax abro

7、ad is a good reference to us.Countries in the world can be divided into two categories: the federal system and the unitary state. Because of the specific situation is different, the level of economic development, cultural and historical traditions, political and economic system is different, the deg

8、ree of financial centralization and decentralization is not the same, the local government tax managementapproach is unique. The establishment of the market economy and the tax sharing system in China are all from the successful practices of somecountries in the United States and Japan. The followin

9、g are the comparative analysis of the local taxes in the United States, Japan and china.I. local tax system of the United States and its characteristics1. The local tax system in the United StatesThe United States is a federal state, and the United States Constitution divides the United States gover

10、nment into three levels: federal, state and local. And three levels of government to adapt to, tax revenue is also implemented three levels of management. Governments at all levels have definite powers and independent taxation power. Its basic features are:First, the tax on the federal tax, state ta

11、x and local taxes, since the system, governments at all levels have home taxes,the main categories of tax sharing. The federal tax system on personal income tax, corporate income tax and social insurance tax three tax as the main body, supplemented by the consumption tax, estate and gift tax, tariff

12、;state tax system is based onsales tax, income tax, supplemented by personal income tax, corporate income tax, consumption tax, inheritance tax and other taxes; local government tax system to the property tax as the main body, supplemented by sales tax, personal income tax and other taxes and fees.

13、The state government is the main source of income of sales turnover collection, production and sales turnover accounted for 58.3%. of the state government levy this tax directly to the business of the goods or services, the utility model has the advantages of the state government can lower nominal t

14、ax rate and to ensure that the cost of large income, tax effects are strong, provide a stable source of tax revenue for the state government. Due to the fixed assets on behalf of a rather long form of capital investment, which can be a rich source of local government, so the property tax in the loca

15、l government revenue in the proportion of 75.98%. of the three tax system showed that, between the United States government tax division is not absolute, someof the major taxes shared by the central and local tax revenue. The tax sharing way of division of income, which is a prominent feature of Ame

16、rican tax system. From the three levels of government to levy taxes and personal income tax, corporate income tax, payroll tax, sales tax, consumption tax; by federal and state governments to levy taxes to the estate and gifttax; by stateand local governments to levy taxes on property tax. Since the

17、 70s of this century, the proportion of local tax revenue (state and local government taxes) has been maintained at around 40% of the total tax revenue.Second, the tax revenue is highly dispersed, and the local government independently exercises the legislative power and the tax administration autho

18、rity that belong to the government at the same level. First, the federal, state and local three councils can determine their own tax system within the scope of the federal constitution. Federal taxes are legislated and executed by the federal government; state taxes are legislated by the state gover

19、nment; local taxes are legislated by local governments. This makes the United States form a unified federal tax system and the coexistence of different state and local tax systems. The state and local tax policies vary greatly. For example, in 50 states in 7 states do not levy personal income tax, e

20、ven in the same state,Tax power is not uniform. In New York, the city of New York on the personal income tax, and other towns in the state are not levied; the sales tax is the main source of state tax, the state average accounted for more than 30%of the income, but specific to the States but differe

21、nt, some as high as 40% or more, some only accounted for about 8% of the national real estate tax; not only around the tax rate level of disparity, and the valuation methods are not the same. The federal, state and local governments have a set of tax collection and management institutions, and the c

22、ollection and management methods have their own characteristics. The federal finance ministry sets up the Internal RevenueBureau, which distributes federal taxes throughout the United States, and local governments, such as cities and towns, also have their own collection and administration instituti

23、ons, which levy their respective taxes. In this way, a taxpayer often pays taxes to several taxauthorities at the same time. The State Administration in different ways, somestates commissioned by the Federal Bureau of internal revenue levy personal income tax, some states by the State Tax Bureau on

24、behalf of the local levy personal income tax and corporate income tax, as well as state and local sign points.Third, diversified sharing of tax sources, coordination and top-down subsidy system. For the relationship between the three levels of government to coordinate the sharing with complex source

25、s, methods, mainly through the United States tax levied taxes levied, tax deduction, tax credits, tax exemption to be adjusted; to compensate for lack of state and local government expenditure at the level of tax revenue by charging, the United States to implement the top-down subsidy system, i.e. t

26、he federal state and local payment of federal grants, and state of the local government issued the state grants.Two, Japans local tax system and its characteristicsJapan is a unitary state, the implementation of centralized system, local administration is divided into the prefectures and municipalit

27、ies in two, the Japanese tax also central prefectures and municipalities in three level management, but the local tax authority is small, its characteristic is:First, the tax categories are divided into the national tax, the county tax and the city village tax, each level of the government to the tw

28、o types of taxes as the main category of taxes. The Japanese local tax is divided into two parts: the county tax and the municipal tax. The central and local taxes are divided by the Congress. The principle of the division of local taxes is based on the division of powers, based on the principle of

29、benefit, and between the categories of taxes. According to the current tax system, there are 59 kinds of taxes in Japan, of which there are 15 kinds of tax in the prefectures and prefectures. There are 17 kinds of taxes belonging to the municipalities and villages. The tax system of all levels of go

30、vernment adopts double main structure. The tax system takes the personal income tax and the corporate income tax as the main body, and the county tax is the main body of the residents tax and enterprise tax; the city village tax is the main body of the residents tax and the fixed assets tax. The rea

31、son is that some tax is less affected by the external factors, the income is stable, can basically guarantee the main expenditure at all levels of government, the central and local tax allocation pattern was 2/3 and the proportion of 1/3.Second, the tax law enacted by Congress, the cabinet for the i

32、mplementation of the tax law and the formulation of government decrees, are prefectures, counties and municipalities, villages and other local governments, according to decree formulation regulations. Japan in the tax management system, emphasis on centralization of power, the tax legislative power

33、are returned, the tax law are subject to congressional approval, the local independent management of local tax authority, but shall be formulated by the state local tax law restrictions, the principle of tax levied by local government only statutory taxes listed in place in the tax law. However, whe

34、n the local government is unable to reach the branch, the general tax can be established outside the statutory tax category, but the levy and adjustment of the tax must be discussed and approved by thelocal council and approved by the central government. The normal rate of most of the taxes imposed

35、by the local tax (standard rate) are prescribed by the local law, but for some specific categories of taxes, such as prefectural tax business tax, vehicle tax, municipal tax resident tax and fixed assets tax and other taxes, all the provisions ofthe tax rate limit.There are also some local taxes wit

36、h a national uniform statutory tax rate, and no place to change itself, such as vehicle purchase tax, gas tax, business income tax, etc. This is the case. In addition, there are some categories of taxes in the local tax. There is no legal provision for the tax rate, which is determined by the local

37、authorities, such as statutory or general taxes.In the tax collection and administration, Japans tax authorities are divided into the national tax system and the local tax system, and the three governments have their own tax authorities, each collecting the tax of the government at the corresponding

38、 level.Third, unique tax adjustment system. In Japan, though much of the tax is levied by the central government, most of the revenue is spent by local governments. Therefore, Japan has a unique system of tax re adjustment to make up for the deficiency of local tax revenue. The system allocated by t

39、he state tax, state tax and Expenditure Assignment of three forms of gold.Three, our countrys local tax system and characteristicsSince the implementation of the tax sharing system in 94 years, Straighten out the distribution relationship between the central and local governments. China has been the

40、 implementation of centralized managementsystem, the regime is divided into central, provincial and municipal (county) level three, central tax, tax sharing and local tax legislative power is concentrated in the central, to ensure that the central regulation of the economy. The tax classification ad

41、ministration, central tax and tax shared by the central tax authorities responsible for the collection, sharing tax share, by the central tax authorities directly into local coffers, local taxes levied by the local tax authorities in charge.First, a more thorough classification of tax measures, the

42、main taxes to the central, sporadic sources of tax to the place.Establish two central and local tax systems. Fixed income of central finance including customs duties, value-added tax and consumption tax, the corporate income tax, local banks and foreign banks and non bank financial enterprise income

43、 tax, the railway department, the bank, the insurance companyfocused on income (including pay business tax, income tax, profit and tax on city maintenance and construction etc.). The export tax refund of foreign trade enterprises shall be borne by the central government except that the 20%parts of t

44、he region have already been charged in 1993 and listed in the local central committee.Fixed income of local finance including: business tax(excluding the railway sector, the bank, the insurance company focused on business tax payable), local enterprise income tax (excluding the local and foreign ban

45、ks and non bank financial enterprise income tax), local enterprises turned a profit,urban land use tax, personal income tax, fixed asset investment tax, city maintenance and construction tax (excluding railway sector, the bank and the insurance company on the pay part), property tax, travel tax, sta

46、mp tax, slaughter tax, agricultural tax, agricultural tax and special land income levy occupation tax, deed tax, inheritance tax and gift tax, land value-added tax, state-owned land transfer income etc.The central government and local finance share revenue, including value-added tax, resource tax an

47、d securities transaction tax. Value-added tax central to share 75%, local share 25%, resource tax divided by different resource categories, land resources tax as a local income, marine oil resources tax as central revenue. The securities exchange tax is shared between the central government and the

48、local authorities 50%.Second, the tax is highly concentrated, local mobile power is smaller.The legislative power of tax revenue in our country is relatively centralized. For a long time, the planned economy has been implemented in China, and the traditional system can hardly be completely reversed

49、in the initial stage of market economy. The legislative powers of central tax, share tax and local tax should be concentrated in the central authorities, so as to ensure that the central government needs to adjust the economy. Both the central tax return, the sharing of local taxes, the tax laws and

50、 the main policies, including the right to levy and the scope of Taxation, are uniformly stipulated by the central government. The specific regulations shall beformulated by the Ministry of finance or the State Administration of taxation. Local governments can only be implemented in accordance with

51、national tax policies and decrees. But there is also a certain degree of maneuver. For example, the Levy of vehicle and vessel tax, property tax and stop sign are decided by the provincial peoples government. Some local taxes shall be reported to the provincial tax authorities for approval according

52、 to certain powers.Third. Organizational structure. The 94 years since the implementation of the tax system, set up the tax system, which is a provincial and County State Administration of Taxation, the implementation of vertical and vertical managementof funds, and is responsible for the central pa

53、rt of the tax sharing income tax revenue; a local tax system, the implementation of vertical management and horizontal management personnel by fees, the burden of local tax revenue.Three, comparative analysis and Enlightenment of tax system in several countries.Because of the different national cond

54、itions, the local tax system of each country also has its advantages. From the comparative study of the local tax system in these countries, we can sum up the following points:1, from the overall structure of the tax system, the above-mentioned countries have paid attention to the importance of the

55、local tax system in the entire tax system. The foreign tax system mainly from the perspective of efficiency and benefit, the tax administration division ofclear and concise, pay attention to the government at all levels of responsibility, right and benefit combine with their own characteristics and

56、the nature of the tax division of the government sources, each level of government have their owntax, to the unity of powers and financial authority the principle of determining the tax revenue distribution share. Local public demand is provided by local governments, while local governments financia

57、l resources are closely related to local taxation. This not only reflects the scientific nature of tax management, and fully mobilize the enthusiasm and initiative of the government finance and taxation. Therefore, the local tax has the following characteristics: first, income stability. Governments

58、 at all levels have home tax, and local tax revenue does not fluctuate greatly with the boom, and has a fairly fixed source of income. Growth flexibility. Local taxes mayincrease as the population, income, or inflation increases in this region.Chinas local tax is especially important to the third in

59、dustry. The economic development requires a rise in the proportion of the third industrial structure and a broad prospect for the growth of the local tax. Tax burden fairness. Tax neutrality requirements: the rich pay more and the poor underpaid or not paid, embodies the principle of benefit. The proportion of individual income tax in our country is increasing day by day. It is a kind of tax with great potential for local tax. The principle of fairness is prominent, and the key is howto manage a