我国银行业增值税制度的选择

发布时间：2018-05-16 13:24

本文选题：银行业 + 增值税　；参考：《西南财经大学》2014年硕士论文

【摘要】：我国是以银行为主的金融格局,银行业资产规模占据了金融系统的大部分的份额,远超资本市场和债务市场,其功能和影响力也是其他金融市场远不能比拟的。银行业可以为经济的发展持续性的提供资金,还能够为市场分散风险,另外银行还具有分配资源、改善企业支付系统的功能。这些功能使得银行和实体经济产生紧密的联系,一荣俱荣、一损俱损。2014年的两会刚刚落幕,在李克强总理作的政府报告中,多次提到产业结构调整、优先发展生产性服务业。银行业作为重要的生产性服务行业,对我国实体经济的发展发挥着巨大的作用,所以应优先重视银行业的发展,从各个方面全力支持。因此优化金融资源配置、促进银行快速发展,让银行更有力的支持实体经济、推动中国经济健康、持续、稳定发展是一种社会共识,也是中央政府所提倡的,正如两会报告中提出的目标,加快产业结构调整、优先发展银行服务业。但是我国银行业的发展面临着营业税制的约束,由于营业税本身的弊端,现行税制无法支持银行业的发展以及规范和正确引导银行业的市场行为,从而导致我国银行业一直无法做出突破,甚至还面临着风险。因此,银行业营业税制改革成为了各界关注的焦点,也是我国亟需解决的问题。而从国际经验来看,银行业增值税制度已成为国际化的制度,增值税由于具有中性、效率和消除重复征税的特点,逐渐的被越来越多的国家重视和采纳,并渐渐形成了多样化的征税模式。一般而言,大部分国家对直接收费的金融服务采用标准税率征收增值税,同时允许银行抵扣为提供这一服务所发生的增值税进项税额,这是因为这类服务价值明确,易于计算,符合增值税发票抵扣制度的要求,征管简便而不会增加纳税人的遵从成本和税务部门的执行成本。但对于金融中介服务和间接收费金融服务,如信贷、保险、证券、基金等采取免税政策,这是因为这类业务具有特殊性,很难确定这类业务的价值增值部分,以致无法计算出课税依据,使得进项税额抵扣制度难以实施,另外免税政策还可以鼓励社会资本流向银行业、促进银行的发展,为金融服务的创新和金融市场的发展创造条件。最后对于出口型金融服务,国际上的通行做法是对这些出口服务适用零税率,即在给予这些出口服务免税的同时,允许银行抵扣为提供这些服务所承担的全部进项税额,对出口金融服务实行零税率,可以鼓励银行出口,提高本国银行业在国际上的竞争力,促进本国金融服务的海外扩张。本文正是基于上述情况,通过研究国际化、多样化的银行业增值税制度,结合我国现实国情,探讨适合我国银行业增值税制度的选择。本文主要运用了文献研究法、国际比较法、行业比较法、定性分析法等方法对文章的论题进行研究。首先,文献研究法是本文主要采用的方法,通过查阅国内外大量相关文献,详细全面的了解国际上现行的银行业税收制度,在对这些文献作总结陈述的基础上,从而得出了我国学者在银行业税制改革方面的研究深度和成果,并在此基础上发现研究中出现的问题及空白,借此明确了自己的研究方向和关注的重点。其次,国际比较法侧重于国内外银行业税收制度的比较,以此来发现彼此间的差异以及各自的优缺点。国际比较法贯穿于全文,不仅出现在文献综述中加以论述各国银行业税收制度,还体现在我国银行业税制改革的国际经验借鉴方面,同时还涉及最后的难点及对策。再次,行业比较法主要是用于比较银行业与其他行业的税负状况,从而得出银行业税负高低的事实情况,进而阐明我国银行业税制改革的方向。最后,定性分析法主要是用于理论分析,通过研究资料归纳得出自己需要的理论。定性分析法也贯穿于全文,从文献综述到国际经验介绍再到我国银行业增值税制度的选择,都运用了定性分析的方法,以此来指出问题、阐明观点、提出解决措施。本文的主题是我国银行业增值税制度的选择以及难点分析与对策建议,文章分以下四个部分阐述：第一部分,导论。这一部分主要阐述的是本文的研究背景及研究对象、本文的研究思路和研究方法、文章的创新与不足之处以及文献综述即国内学者对这一问题的相关讨论及形成的研究成果。第二部分,银行业增值税制度的国际经验评价。这一部分主要研究的是国际上对银行业采取的税收制度,包括对银行业不征增值税的税收制度和对银行业征收增值税的税收制度,其中主要介绍了对银行业征收增值税的情况下外国采取的不同课税模式,并对这些模式进行了优劣评价,为后文我国银行业税收制度的选择打下理论基础。第三部分,我国银行业增值税制度的选择。这一部分是本文的重点,先从税收原则谈及我国银行业税收制度的选择问题,然后再逐一分析我国为什么要选择银行业增值税制度以及选择哪种增值税征收模式。这一部分从正反两方面加以论证,详细阐述了各种模式的优缺点以及与我国现实国情的契合度,通过比较得出最后的结论,即我国应对银行业征收增值税并选择零税率模式。第四部分,难点及对策。这一部分提出了在我国银行业改征增值税过程中将会面临的困难,如银行业会计核算体系问题、直接收费金融服务适用税率问题以及财政收入减少的问题等,在分析各个问题之后相应提出了笔者个人的一些观点。本文通过定性分析得出我国应对银行业征收增值税,而零税率法是最适合我国银行业增值税的征税方法。首先,零税率法下银行核心金融业务不仅免税而且还可以抵扣相应的进项税额,避免了进项税额在免税服务与应税服务之间的分摊,大大降低了银行的税收遵从成本和税务当局的征管成本；其次,零税率和免税不同,零税率保证了增值税征收链条的完整性；最后,零税率法允许银行抵扣为购进服务而缴纳的所有进项税额,彻底的消除了重复征税,有效降低了金融机构的税负,使得金融服务和其他出口商品一样处于零增值税价格,有利于提高本国金融部门的竞争力,促进本国金融业的扩张。虽然零税率的优势是有一定代价的,零税率允许银行进项税额全部扣除,同时又使得国家对核心金融业务征不到税收,其导致的必然结果就是国家财政收入的减少,这无疑向各国提出了考验,或许也正因为此,零税率法才没有被所有国家采用。但是本文在最后章节提出了以税制本身缓解财政收入减少的危机这样的政策建议,以保障各地公共服务的供给。本文最大的创新之处在于系统的分析了我国银行业如何在借鉴国际银行业税收制度模式情况下,选择适合我国国情的银行业增值税零税率模式,并初步讨论了零税率模式下的制度框架,包括零税率的适用范围、直接收费金融服务适用税率的选取等,深入分析了我国银行业在改征增值税的变革过程中面临的难点,并开创性的提出应将零税率模式下的制度设计同解决银行业“营改增”过程中面临的难点相结合,如直接收费金融服务适用税率选取17%的标准税率可以适当缓解因税制改革产生的财政收入大幅度下滑的问题等。本文最大的不足在于无法进行定量分析并设计出零税率模式下符合我国国情的制度框架。税制的设计本身就是一项繁杂的工作,需要考虑各个行业、各个领域以及不同行业内部的各种因素,需要国家各个机关,税务机关、统计局、银行等之间的相互协作,还要搜集大量的数据、运用先进的统计方法计量才能制定出科学合理、符合税收原则、国家产业政策及结构调整导向的银行业增值税制度,并将其纳入整个增值税制度体系当中。限于笔者的银行实务水平、微观数据来源不畅及数据处理能力不足而导致对制度设计心有余而力不足。同时由于笔者自身学术修养不够,无法对整篇文章进行全面把控,无法面面到位、不出差错,从而导致存在很多疏漏和考虑不周的地方,这些有待于以后进行更加深入的研究和探讨,也希望各位老师多多批评、指正。
[Abstract]:China is a financial structure based on banks. The scale of banking assets occupies most of the share of the financial system. It is far beyond the capital market and the debt market. Its function and influence are far beyond the other financial markets. The banking industry can provide funds for the sustainable development of the economy, and also be able to disperse the risks for the market. Banks also have the ability to allocate resources and improve the function of the enterprise payment system. These functions have made the banks and the real economy closely linked. The two meetings of the.2014 years have just ended. In the government report of prime minister Li Keqiang, the industrial structure is adjusted and the production service industry is given priority. The production service industry is playing a great role in the development of China's real economy. Therefore, we should give priority to the development of the banking industry and support all aspects of it. Therefore, we should optimize the allocation of financial resources, promote the rapid development of the bank, let the banks support the real economy more forcefully, and promote the healthy, sustained and stable development of China's economy. A social consensus is also advocated by the central government. As the goals put forward in the two sessions report, we should speed up industrial restructuring and give priority to the development of banking services.
However, the development of China's banking industry is constrained by the business tax system. Due to the drawbacks of the business tax itself, the current tax system can not support the development of the banking industry and standardize and correctly guide the market behavior of the banking industry. Thus, the banking industry in our country has been unable to make a breakthrough and even faces the risk. Therefore, the reform of the banking business tax system reform. It has become the focus of attention from all walks of life, and it is also an urgent problem for our country to solve.
From the international experience, the banking value-added tax system has become an international system. As a result of the characteristics of neutrality, efficiency and elimination of duplication of Taxation, value-added tax is gradually taken seriously and adopted by more and more countries, and gradually forms a diversified mode of taxation. Generally speaking, most countries use direct charge financial services. The standard tax rate levies VAT and allows banks to deduct the added value of VAT to provide this service, which is because these services are of clear value, easy to calculate, conform to the requirements of VAT invoice deduction system, and are easy to expropriate without increasing the taxpayer's compliance costs and the executive costs of the tax department. Intermediary services and indirect charge financial services, such as credit, insurance, securities, and funds, are adopted tax exemption policies, which are due to the particularity of this kind of business. It is difficult to determine the value added part of such business so that it is impossible to calculate the tax basis, which makes the tax deductible system difficult to implement, and the tax exemption policy can also encourage social capital. This is going to the banking industry, promoting the development of the banks, creating conditions for the innovation of financial services and the development of the financial market. Finally, the international practice is to apply zero tax rates to these export services, that is, to allow these services to be deducted for the provision of these services while giving these export services tax exempt. The total entry tax, the zero tax rate on export financial services, can encourage the export of banks, improve the competitiveness of the domestic banks in the world, and promote the overseas expansion of their financial services.
This article is based on the above situation, through the study of internationalization and diversification of the banking VAT system, combined with the actual conditions of our country, to explore the choice of value-added tax system suitable for China's banking industry.
This paper mainly uses literature research, international comparison, industry comparison, qualitative analysis and other methods to study the thesis. First, the literature research method is the main method used in this article. By consulting a large number of relevant documents at home and abroad, the current banking tax system in the country is thoroughly understood, and the documents are made in the literature. On the basis of the summary and statement, the research depth and achievements of Chinese scholars in the reform of the banking tax system are obtained, and on this basis, the problems and gaps in the study are found and the focus of their research is clarified. Secondly, the international comparative law is more important than the comparison of the domestic and foreign banking tax system. To find out the differences between each other and their advantages and disadvantages. The international comparative law runs through the full text, not only in the literature review, but also in the tax system of the banking industry in all countries, and also in the international experience of the reform of the tax system of the banking industry in our country, and at the same time, it also involves the final difficulties and countermeasures. This paper compares the tax burden between the banking industry and other industries, thus draws the fact that the tax burden of the banking industry is high and low, and then clarifies the direction of the reform of the tax system of the banking industry in our country. Finally, the qualitative analysis method is mainly used in theoretical analysis, and concludes the theory that it needs through the research data. Qualitative analysis method is also run through the full text, from literature review to The introduction of international experience to the choice of the VAT system in China's banking industry has used the qualitative analysis method to point out the problems, clarify the views and put forward the solutions.
The theme of this paper is the choice of China's banking value-added tax system and its difficulties and countermeasures. The article is divided into four parts:
The first part is introduction. This part mainly expounds the background and research object of this article, the thinking and research method of this article, the innovation and inadequacies of the article and the literature review, that is, the relevant discussion and the results of the research on this issue by domestic scholars.
The second part is the international experience evaluation of the banking VAT system. This part mainly deals with the international tax system on the banking industry, including the tax system for the non value-added tax on banks and the tax system for the collection of value-added tax on the banking industry, which mainly introduces the foreign adoption of the collection of value-added tax on the banking industry. Different tax modes are evaluated, and the advantages and disadvantages of these models are evaluated, which will lay a theoretical foundation for the selection of banking tax system in China.
The third part, the choice of the bank value added tax system in China. This part is the focus of this article. First, we talk about the choice of the tax system of China's banking industry from the tax principle, and then analyze why China should choose the banking value-added tax system and choose which kind of value-added tax collection mode. This part discusses the two aspects of the positive and negative aspects. In detail, the advantages and disadvantages of various models and the agreement with our country's actual conditions are expounded in detail, and the final conclusion is drawn through comparison, that is, China should levy the value-added tax on the banking industry and choose the zero tax rate model.
The fourth part, difficulties and countermeasures. This part puts forward the difficulties that the banking industry will face in the process of adding VAT, such as the problems of the accounting system of the silver industry, the applicable tax rate of direct charging financial services and the reduction of financial revenue, and then puts forward some personal views after the analysis of the various problems.
Through qualitative analysis, this paper concludes that China should levy a value-added tax on the banking industry, and the zero tax rate law is the most suitable tax method for the value-added tax of China's banking industry. First, the bank core financial business under zero tax rate is not only duty-free but also can deduct the corresponding income tax, avoiding the difference between tax duty and taxable service. It greatly reduces the cost of the bank's tax compliance and the cost of tax administration. Secondly, the zero tax and tax exemption are different, and the zero tax rate ensures the integrity of the chain of value-added tax. Finally, the zero tax law allows the bank to deduct all the amount of tax paid for the purchase service, completely eliminating the duplication of taxes and reducing the gold effectively. The tax burden of the organization makes the financial services be in the same price as the zero value added tax, which is beneficial to the competitiveness of the domestic financial sector and the expansion of the domestic financial industry. Although the advantage of the zero tax rate is at a price, the zero tax rate allows the total deductions of the entry tax of the bank and the state to the core financial industry. The inevitable result is the reduction of the state's fiscal revenue, which is undoubtedly a test to all countries. Perhaps it is precisely because of this, that the zero tax rate law has not been adopted by all countries. However, in the last chapter, this article puts forward a policy suggestion that the tax system itself can alleviate the crisis of the decrease of fiscal revenue, in order to guarantee all parts of the country. The supply of public services.
The main innovation of this paper is the systematic analysis of how China's banking industry selects the zero tax rate model suitable for the national conditions of our country, and discusses the system framework under the zero tax rate model, including the scope of application of zero tax rate, and the application of direct charge financial services. The selection of tax rate and so on, the difficulties in the reform of China's banking industry in the process of VAT transformation are deeply analyzed, and it is proposed that the system design under the zero tax rate model should be combined with the difficulties encountered in the process of "increasing the business of the banking industry". For example, the standard tax rate of 17% of the applicable tax rate for direct charging financial services can be selected. Appropriately alleviating the sharp decline in revenue generated by tax reform.
The biggest shortage of this article lies in the inability to carry out quantitative analysis and design a system framework that meets the national conditions of our country under the zero tax rate model. The design of the tax system itself is a complex work, which needs to consider various industries, various fields and various internal factors in different industries, and need the various organs of the state, the tax authorities, the Statistics Bureau, the bank and so on. The cooperation between each other and the collection of large amounts of data and the use of advanced statistical methods can make a scientific and rational, tax principle, national industrial policy and structural adjustment oriented banking VAT system, and incorporate it into the whole system of value-added tax system. Limited to the author's banking practice and micro data sources Lack of data and processing power results in insufficient system design.
At the same time, because of the author's own lack of academic accomplishment, it is impossible for the whole article to be fully controlled, unable to be in place, without error, which leads to a lot of omissions and unconsidered places, which need to be further studied and discussed in the future, and we also hope that teachers will criticize much more.

【学位授予单位】：西南财经大学
【学位级别】：硕士
【学位授予年份】：2014
【分类号】：F812.42;F832.33

【参考文献】