291.E关于增值税的税收筹划认识与思考 外文原文

1、value-added taxes in developing and transitional countries: lessons and questionsrichard m. bird university of toronto - joseph l. rotman school of management abstract：the value-added tax has, in recent decades, become the most important single tax in most developing and transitional economies. this

2、 paper reviews some problems that have emerged as important as more experience has been gained with how vats really work in many such countries and suggests some lines of research that need to be explored further to overcome those problems. 1. introduction few fiscal issues are more important in dev

3、eloping and transitional economies (dte) than the value-added tax (vat). over the last few decades, vat has swept the world. the principal reasons for the rapid spread of this form of taxation were, first, the early adoption of this form of taxation in the european union (eu) and, second, the key ro

4、le played in spreading the word to dte by the international monetary fund (imf) in particular and by international agencies and advisors more generally. the success of vat in the eu showed that vat worked. the consistent support and advocacy of this form of taxation by the imf and others in a variet

5、y of countries, first in latin america, and then around the world, encouraged and facilitated the adoption of vat by countries with much less developed economic and administrative structures than those in the original eu member states. at the same time, for various reasons of their own, all the non-

6、eu countries of the oecd apart from the united states have also, one by one, introduced vats, most recently australia in 2000. of course, to a certain extent, as the background paper (itd, 2005) observes, the vat label covers a variety of taxes in different countries. countries that belong to the eu

7、 have necessarily all adopted the same model of vat, essentially as laid out by the sixth directive of 1977, although some important differences remain between vats in eu member states (mathias, 2004). other countries influenced by the eu such as the recent and prospective accession countries of cen

8、tral and eastern europe have also largely followed this model. elsewhere in the world, however, while the influence of the eu model (and some member-state variants) is clear in, for example, some former colonies of eu member states, other models have been developed and adopted, notably in new zealan

9、d and japan. equally importantly, the imfs fiscal affairs department, the leading change agent in this respect for in much of the world has over time evolved what is essentially its own model of an appropriate vat for dte, as set out initially, for instance, in tait (1988, 1991) and most recently in

10、 ebrill et al. (2001). while vat countries have introduced many local variations into whatever basic model they may have started from for a small sample of early country experiences, see e.g. gillis (1990), oea (1993), yoingco and guevara (1988), and oecd (1998), and for a sample of the discussion i

11、n an important current case, that of india, see e.g. shome (1997), chelliah (2001), and empowered committee (2005).,as victor thuronyi (2003, p.312) has recently noted, “ while there are differences in vat from one country to another, compared with the income tax vat laws are remarkably similar.”whe

12、n dte have a vat, it is invariably among the most important sources of government revenue. indeed, anyway one cares to look at it vat has clearly been an enormous success. not only has it swept the world almost clear of contending general sales taxes but in many dte it dominates the income tax as th

13、e mainstay of national finances. no previous fiscal innovation has been adopted in such a wide variety of countries so rapidly. not all is sunshine in vatland, however. clouds of varying sizes and shapes seem to be looming on the horizon in all vat countries but perhaps particularly in dte that have

14、 become increasingly dependent on vat and hence more vulnerable to potential problems. some of these problems have always been inherent in the structure and operation of vats but are exacerbated by the increased fiscal weight being placed on the many dte under pressure for new fiscal revenues for ex

15、ample to offset revenue losses from tariff reductions needed to accord with wto requirements. it is thus perhaps time for a new look at the role of vat in dte.specifically, are the vats now in place in most dte as good as they could be in economic, equity, and administrative terms? must good vats in

16、 such countries always follow the same pattern? must every dte have a vat? can all dte administer a vat sufficiently well to make the introduction of the tax worthwhile? is a vat always the best way to respond to the revenue problems arising from trade liberalization? can vats be adapted to cope wit

17、h the rising demands in some countries, especially federal countries, for more access to revenues by local and regional governments? can they deal with such new problems as those arising from changes in business practices with financial innovations and digital commerce? the answers to such questions

18、 are not only critical to the fiscal stability of many dte but also to their economic growth and development. are the vats already in place in many dte the efficient, simple, revenue-raisers some claim? or, as others argue, are they so inequitable as to exacerbate social and political tensions? does

19、 vat provide a way to tap the informal sector or does it instead tend to expand that sector? no brief paper can answer such complex questions, of course, so the objective of this paper is considerably more modest. taking the background paper prepared for this conference (itd, 2005) as its starting p

20、oint, the aim of this paper is simply to provide a few additional reflections on some lessons that seem to emerge from experience to date with vat in dte -countries in which, for the most part, tax reality is much more dominated by administrative capacity on one hand and political necessity on the o

21、ther than in the european home of so much vat experience and thinking. there is indeed much room and need for sharing experiences between developed countries and dte, but there are also some important differences that need to be explicitly taken into account when doing so. to paraphrase the conclusi

22、ons of the late jean jacques laffont (2004) in a recent survey of public utility regulation in dte, not only do we as yet have surprisingly little solid empirical knowledge of some critical factors but the relevant economic theory also remains rather sketchy and we know even less about the relevant

23、political economy context. for the most part, this paper simply attempts to flesh out these observations in a little more detail with respect to vat in dte. in doing so, it should perhaps be noted that although the points made are stated in general terms for the most part they are inevitably shaped

24、by the authors limited personal experience with various aspect of vats in a number of dte over the years. in a sense, however, this is perhaps not a limitation since it is precisely through closer analysis of, and reflection on, the experience of such case studies that we can best discern the real c

25、hallenges facing vat in dte and the questions that most need further attention. such at least, is the approach taken here. in contrast to the disclaimer in the background paper, it should perhaps be explicitly noted that, while the author has learned a great deal about these topics from the staff of

26、 the world bank, the imf, and the oecd and is in addition grateful to pierre-pascal gendron for helpful comments, he alone is solely responsible for all views expressed in this paper.2. lessons from experienceat the risk of repeating some of the many good and sensible things said in the background p

27、aper, this section discusses briefly five major lessons that emerge from the extensive experience with introducing and implementing vats in dte. first, and most importantly, as the background paper says, vat works. despite some recent criticisms by reputable analysts, for the most part it remains tr

28、ue that, if a country needs or wants a general sales tax, it is well advised to have a vat. secondly, nonetheless vat does not always work well in many dte, principally because some are simply not ready for self-assessment. thirdly, what this suggests for tax design is what may be called the nosfa p

29、rinciple - no one size fits all - although it may be that several sizes (patterns) of vat may prove suitable for different groups of countries in similar circumstances. fourthly, the major lesson for tax administration that experience in dte suggests is that the oft-cited 18-24 months needed for suc

30、cessful vat implementation vastly understates the nature and time scale of the task in many countries. many dte cannot be simply, as it were, given a good vat administration: they need to grow it themselves and the process may take a long time in some cases. finally, since tax policy is always about

31、 politics as much or more than it is about tax design and administration, we must always remember that, as ken messere (1999, p.342) once said in a discussion of oecd countries, tax policy “is about trade-offs, not truths.” to some extent at least, the future of vat in dte lies in much closer unders

32、tanding of the critical politicaleconomy dimension of vat policy and administration. 2.1 vat worksas the background paper shows, vat is by no means necessarily the money machine that it has sometimes been called. the effects on revenue of introducing a vat in particular contexts remains a matter ope

33、n to interpretation and question, as recently underlined by some who have questioned the capability of vat to replace revenues from trade liberalization in some dte (e.g. rajaraman, 2004). while it is true that there may indeed be a somewhat stronger case for retaining some taxation on international

34、 trade on revenue grounds than has been conventionally asserted, this case rests less on defects of vat as such than on the assumed relative inefficiency of vat administration compared to border tax administration (see also section 2.4). if a vat can be administered adequately, the conventional conc

35、lusion that it offers the best way for a country to make up revenue losses from trade liberalization holds, though perhaps in less sweeping terms than originally argued on this, compare the rigorous analysis in keen and ligthart (2002) with the equally rigorous, but different, analysis in keen and l

36、igthart (2004).indeed, the equally conventional conclusion that a vat is the most economically desirable and administratively effective way in which to collect a given share of national income through a general consumption tax also holds -provided, again, that the capacity exists to administer vat a

37、dequately. when a country introduces a vat, whether to replace another form of general sales tax or as a new tax, there need not necessarily be an aggregate increase in revenues (either from consumption taxes or in general).as a rule, however, the economic cost of collecting revenues will decline, t

38、hus making society better off. similarly, as with any tax, although increasing the rate of an existing vat rates will neither necessarily increase revenues proportionately nor be costless, it may nonetheless be the economically most sensible way to expand revenue shares in dte, if that is the policy

39、 goal. 2.2 but it does not always workmore generally, as hinted earlier, what is really at issue in such countries is not so much such specific problems - all of which may in principle easily be corrected if desired - but rather the fundamental question of whether they are really ready for the self-

40、assessment approach that the background paper properly asserts is how a good vat works. if a country is not ready in this regard, should if have a vat at all? and, if it does (as many already do), is the best vat for it always the same as the model implicitly set out as a standard in most of the lit

41、erature? the question is discussed further in the next two sections. 2.3. tax design: the nosfa principlea second possibly rewarding approach to explore would be to recast the familiar (if implicit) decision-tree approach to vat by setting out in more detail the implications of different nodal decis

42、ions (e.g. zero-rating) for other design aspects, then working out the optimal sequence of such decisions for particular countries (or groups of countries), and finally assessing how dependent the rightness of particular decisions is with respect to different characteristics of the environment withi

43、n which the vat is expected to function. while of course many elements of such an approach are to be found in the literature (e.g. ebrill, 2001), as yet little has been done to set out the relevant decision-points and their interdependence in a systematic fashion or to quantify them in any meaningfu

44、l way, although the interesting recent work on vat thresholds (keen and mintz, 2003) is a good first step in this direction. many more such steps are needed. 2.4. tax administration: growing into a good vatsecondly, as with respect to tax design, more thought seems needed with respect to what one re

45、ally has to know about a country in order to devise the right implementation schedule for its particular circumstances. what matters most and in what ways? is it the size distribution of the potential tax base? or the relative importance of key base components (such as imports and excise goods) and

46、the degree of administrative control that can realistically be expect with respect to those components? or the level of accounting skills in the potential taxpayer population? or the detailed industry-by-industry flow of vatable items between different sectors and different sized firms? or the capac

47、ity of tax officials to administer an accounts-based tax and in particular attention to audit such a tax? or, perhaps most fundamentally, the degree of existing trust between officials and taxpayers and how quickly (and in what ways) that trust can be built up sufficiently to support a self-assessme

48、nt system? or is it all of the forgoing and more? whatever ones answers to such questions, what seems clear is that one cannot expect success simply by transferring experience from very different developed country settings to dte with fragmented economies, large informal sectors, low tax morale, ram

49、pant evasion, and total distrust between tax administrators and taxpayers. the research agenda with respect to vat administration in dte is thus even larger and probably more important than that with respect to vat design in such countries. 2.5. tax policy is an art, not a sciencein the end, what va

50、t looks like and how it performs in any country inevitably reflects political factors and calculations as much or more than economic and administrative considerations. as a rule, of course, the critical political dimension of the policy process must simply be accepted as given by those directly conc

51、erned with tax design and implementation. nonetheless, it is obviously desirable that they are as fully aware as possible of the manner in which such factors may impact on, and are in turn affected by, such central elements of vat design and implementation as exemptions (see section 3.2 below).to be

52、 forewarned that a particular sector is politically untouchable may, for instance, enable policy designers to be able to work around the problem in a way that does less damage to the tax as a whole than might otherwise be the case a common joke among development economists years ago was along the fo

53、llowing lines: “what difference would it make to development policy in country x if all the political scientists in the world disappeared?” the expected answer, of course, was “no difference at all.” while no doubt serving its intended purpose of making economists feel perhaps a bit more useful (at

54、least in relative terms), this joke is very wrong indeed. as we have begun to understand with the recent upsurge of the political economy literature, few things matter more for better policy design and implementation in any country than deeper understanding of how politics works in that country. som

55、ewhat curiously, however, despite the proliferation of real world examples available for study, few careful political economy studies of vat implementation appear to have been done in dte as yet. as such studies begin to appear, they will in all likelihood often suggest still further questions calli

56、ng for still more scientific (empirical and theoretical) research that may, in the long run, provide more useful advice than can yet be offered to those engaged in the precarious art of policy design and implementation in dte. 3. other issuesmany questions have already been raised about vat in dte,

57、and some possible directions in which to search for answers have been tentatively suggested. in this part of the paper, five issues are singled out for a bit more discussion. section 3.1 raises a prosaic but surprisingly important question: do vat systems generate the information needed both for sou

58、nd analysis and good management? section 3.2 returns to the issue of exemptions mentioned in section 2.2 above, placing it in the more general context of the equity of vat in the circumstances of many dte. section 3.3 focuses on some aspects of the surprisingly controversial questions related to vat

59、 and small business, and section 3.4 continues downward, as it were, into the realm of the shadow economy and asks how effective vat can be in dte in which such activities constitute a critical sector of the economy. finally, section 3.5 raises the question of how, if vat already faces as many problems as discussed here in many dte, it can possibly cope with such changes as those associated with the looming rise of e