本报告从税收原则出发,首先,对西方税收原则的发展概况、新中国成立以来至党的十八届三中全会确立的税收原则变迁情况进行分析。其次,运用税收原则理论,从PPP项目全生命周期各阶段特点及其复杂性出发,分析了在PPP税收优化路径设计中运用税收原则的必要性及可行性。再次,立足“统一税制、公平税负、促进公平竞争”,分析PPP税收管理现状,指出因为缺乏专项税收政策规定而产生的税收“不便利”、税收征管空白、重复征税以及没能针对PPP项目特有风险发挥调控作用等诸多问题。最后,运用税收原则,对PPP项目税收配套政策提出了消除税收“不便利”、遵循税收公平原则、坚持效益原则、兼顾税收效益与稳定原则等四条优化建议。
<<First of all,in this dissertation,development of western tax principles and the transition of tax principles from the founding of China to the Third Plenary Session of the 18th CPC Central Committee was studied based on the tax principle. Next,the necessity and feasibility of applying tax principles in the design of PPP tax optimization path by the theory of tax principles was analyzed according to the characteristics and complexity of each stage of the whole life cycle of PPP project. In addition,a lot of problems,including the “inconvenience” of tax revenue due to the lack of special tax policy provisions,the blank of tax collection and management,repeated taxation,and the failure of tax policy to play a regulatory role in response to the unique risks of PPP projects,was pointed out according to the principle of “unified tax system,fair tax burden and promotion of fair competition”. Finally,four optimization suggestions have been put forward for tax policies of PPP projects,including elimination of tax “inconvenience”,realization of tax certainty,avoidance of double taxation,prudent preference and optimization of resource allocation by applying tax principles.
<<Keywords: | Tax PolicyPPP projectTax Principles |