税基侵蚀与利润转移(BEPS)
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OECD发布全球税收争议预防及解决最新成果,中国成绩亮眼:中国税务快讯
KPMG· 2025-11-13 07:10
Group 1: OECD Taxation Insights - The OECD's latest report highlights China's MAP case closure rate exceeds the global average, showcasing effective tax dispute resolution[3] - China's APA closure rate stands at 24.2%, significantly higher than the global average of 18.1%, ranking seventh among jurisdictions[8] - The tax dispute prevention rate in China is 66.7%, well above the global average of 37.8%, placing it fifth globally[8] Group 2: Global Tax Trends - The total number of global MAP cases increased from 2,782 to 2,980, reflecting a growth rate of 7.12%[8] - The average completion time for MAP cases globally is 27.4 months, with transfer pricing cases reduced from 32 months to 30.9 months[8] - The OECD emphasizes the importance of cooperation among tax authorities to enhance tax certainty and prevent disputes[4] Group 3: Future Outlook - Chinese tax authorities are expected to continue engaging with jurisdictions like Italy, the US, Switzerland, Japan, and South Korea to resolve tax disputes[8] - The OECD's best practices are being integrated into domestic regulations by various jurisdictions, indicating a commitment to improving tax administration[7] - The exploration of multilateral frameworks for tax dispute resolution is gaining traction, with a focus on overcoming domestic legal barriers[7]
“机器人税”:重新协商社会契约的现代工具
Jing Ji Guan Cha Wang· 2025-09-30 08:31
Core Viewpoint - The concept of a "robot tax" is emerging as a potential solution to address the economic implications of automation, particularly in terms of tax revenue and social security funding as robots replace human labor [1][2][5] Group 1: Current Status of Robot Tax - No country or region has officially implemented a "robot tax" in any form, although there have been discussions and proposals, such as those by the European Parliament in 2017 and a local proposal in San Francisco [1][5] - Academic circles are actively proposing various "robot tax" schemes, with differing methods aimed at achieving social equity and welfare [1][5] Group 2: Purpose and Justification of Robot Tax - The "robot tax" is viewed as a modern tool for renegotiating the social contract, allowing for a fairer distribution of the benefits derived from automation [2][3] - It aims to address the loss of income tax bases and social security contributions as automation shifts value from workers to capital owners [2][3] Group 3: Implementation Considerations - The most practical approach to defining the tax base would focus on the actual utility generated by technology rather than its physical form, encompassing both physical robots and AI systems [3] - There is a concern that unilateral implementation of a "robot tax" by one country could lead to a decline in competitiveness, suggesting the need for international coordination similar to the "global minimum corporate tax" [7] Group 4: Alternative Policy Options - Various alternatives to a direct "robot tax" are being explored, including the cancellation of excessive capital depreciation policies, wage subsidies, and the establishment of employer-funded training funds [8] - The idea of "automation dividends" or shifting social contributions from wages to consumption or capital taxes are also being discussed as complementary measures [8] Group 5: Global Considerations - Developing countries may require a differentiated global framework that allows them to delay taxation to attract investment, while developed countries could lead the way in implementing such taxes [9] - To prevent the "robot tax" from becoming a tool for base erosion and profit shifting (BEPS), it is essential to link the tax to the actual use of automation rather than just the location of corporate profits [9][10]
特朗普开辟新战线!税收主权战已经打响
Jin Shi Shu Ju· 2025-07-02 13:27
Group 1 - The core issue of the article revolves around the impact of Trump's administration on the global economic order, particularly in the realm of international tax rules and trade [1] - The G7 countries have been forced to accept exemptions for U.S. companies from certain tax rules, indicating a shift in international tax dynamics [2] - The compromise reached may lead to future conflicts, particularly regarding digital taxes, as countries like the UK, France, Spain, and Italy have already implemented similar taxes [3] Group 2 - The U.S. tax supremacy ideology has emerged, with bipartisan support in Washington against foreign extraterritorial taxation [2] - The agreement to exempt U.S. companies from specific rules may set a precedent for future negotiations, raising concerns about the credibility of U.S. commitments [3] - The complexity of the dual taxation system is increasing for multinational companies, leading to greater policy uncertainty and higher cross-border operational costs [3]