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实证分析显示,1994—2005年我国省际人均内外资企业所得税收入分布差异既超过其对应税源分布差异,也超过全部税收收入分布差异。在我国现行财税体制下,尤其在“两法合并”实行法人所得税制之后,应当坚持税收归属与税收来源一致性原则,以“分支机构全面预缴、总机构汇算清缴”为基本模式,以“总机构统算应税所得、按比例进行分配、总分机构分别申报纳税”为补充模式,建立科学的地区间企业所得税收入归属机制。
Empirical analysis shows that the distribution of income tax revenue of domestic-funded foreign-funded enterprises in each province between 1994 and 2005 both exceeded the distribution differences of their corresponding tax sources and also exceeded the distribution of the total tax revenues. Under the current fiscal and taxation system in our country, especially after the implementation of the legal person income tax system by the merger of the two laws, we should adhere to the principle of consistency between the tax ownership and the tax revenue source, adopt the principle of “full payment in advance by the branch offices and final payment by the head office” As the basic model, set up a scientific attribution mechanism of inter-regional corporate income tax revenue based on the principle of “total taxable income calculated by the head office, distribution in proportion, and total score reporting and tax payment by the head office” respectively.