北歐國家採行二元所得稅制對我國個人資本所得稅改革之啟示

Lessons from the Implementation of Dual Income Tax Reforms in Northern Europe

挪威、瑞典、芬蘭等北歐國家於1990 年代初期，採行二元所 得稅（dual income tax）制度，將個人所得分為勞動所得（labor income） 與資本所得（capital income）兩類。其中勞動所得按累進稅率課稅；資本所得按比例稅率課稅，以減少租稅對資本運用造成的扭曲效果，求取租稅效率與公平兩者間的平衡，並已促使其他歐洲國家的資本所得課稅制度跟進改變。因此，本研究建議採行二元所得稅制概念推動國內資本所得稅改革，從低訂定資本所得課稅標準且全面一致化，並擴大資本所得稅基，以改善我國現行資本所得課稅制度，提升資本所得課稅效率；並減輕徵納雙方查緝成本與依循成本，以打造具國際競爭力的租稅環境。

Norway, Sweden and Denmark were among the northern European countries that in the early 1990s adopted a dual income tax system, under which personal income was divided into income from labor and income from capital. The dual income tax system, in which labor income is taxed at progressive tax rates and capital income is taxed at a flat rate, is aimed at reducing the tax distortion effect on capital use, and at seeking a balance between efficiency and fairness. Other European countries have followed this initiative by making corresponding changes to their capital income tax systems. Hence, this paper recommends that Taiwan adopt the dual income tax concept in carrying out reform of capital income taxation. This should involve lowering and comprehensively harmonizing capital income tax standards, and expanding the capital income tax base, to improve the current capital income tax system and enhance its efficiency. Such reform would also lower the costs of investigation and compliance between tax authorities and taxpayers, and help create an internationally competitive tax environment.