2014「國際租稅競爭力指數（ITCI）」評析

Analysis of the 2014 'International Tax Competitiveness Index'(ITCI)

一、全球化經濟下，稅制已成為競爭力的重要因素，美國稅務基金會（Tax Foundation）2014年9月15日首度發表「國際租稅競爭力指數」（International Tax CompetitivenessIndex, ITCI），依租稅負擔與中立性原則，評比OECD34國租稅競爭力，ITCI內容及OECD國家相關做法，正可以做為我國稅制改革之參考。二、ITCI探討（一）非中立性措施（包括高度累進稅率、成本認列限制、繁複稅務作業等）將干擾經濟活動，影響資源配置效率，增加無謂損失。（二）稅率為重要指標，調降稅率有助競爭力，惟特定租稅優惠，可能導致過度投資、政治遊說、稅負移轉等，反而不利競爭力。（三）國際間日益重視企業跨國避稅課題，多數國家訂有反跨國避稅法規，OECD亦將大幅修訂國際稅則，以防堵跨國企業避稅。三、我國租稅競爭力評估（一）我國營所稅及營業稅之稅率遠低於OECD國家，具競爭優勢，惟稅率過低，影響財政收入。（二）我國稅制在綜所稅、股利所得、屬人兼屬地主義、成本認列方法、加值型營業稅門檻等方面，尚有檢討改進空間。四、政策建議（一）我國股利所得適用綜所稅累進稅率並採繁複之設算扣抵法，建議改採單一稅率分離課稅，以降低扭曲效果並簡化稅務作業。（二）建議研究營所稅改採屬地主義之可行性，並參酌OECD國家做法，建立完備之反跨國避稅法規。（三）建議檢討非中立性之租稅措施，允許後進先出法認列成本、擴大適用加值型營業稅及取消貨物稅，並降低薪資所得者稅負。（四）建議在兼顧競爭力前題下，檢討調整營業稅及營所稅之稅率。1.加值稅屬中立性稅制，且我國稅率遠低於OECD國家，可適時檢討調升稅率挹注財源，並做為稅制改革之配套措施。2.我國營所稅稅率低且訂有各種租稅優惠，建議通盤檢討企業實際稅負，適當調整相關規定。

1. In economic globalization, the tax system has already become an important factor of competitiveness. The Tax Foundation first published 'International Tax Competitiveness Index' (ITCI) on September 15, 2014. According to the tax burden with the principle of neutrality, and assessing the tax competitiveness of OECD’s 34 countries, ITCI’s evaluated content and OECD’s national relevant method – these can all be used for the reference of tax system reform in our country. 2. ITCI’s discussion concluded: (1) Non-neutral measures (including highly progressive tax costs, recognized limitations, complicated tax work, etc.) will interfere with economic activity, the impact of resource allocation efficiency, and cause increased deadweight loss. (2) The tax rate is an important indicator - adjusting it lower will help competitiveness, but specific tax incentives may lead to over-investment, political lobbying, transfer taxes and so on, causing unfavorable competitiveness. (3) The issue of transnational payment of duty evasion in enterprises internationally is more and more important. With the majority of countries for the multinational anti-avoidance legislation, OECD will also substantially revise international tariffs in an attempt to prevent taxing multinational corporations. 3. The tax competitiveness of our country is assessed: (1) Our country’s corporate tax and business tax rates are much lower than those of the OECD countries, giving Taiwan a competitive advantage, but if the tax rates are too low, this will influence fiscal revenues. (2) Individual income tax, dividend income, a worldwide system of taxation, cost recognized methods, value-added business tax threshold, etc. are still being examined to identify areas of possible improvement. 4. The policy recommendations: (1) The dividend income of our country is applicable to the comprehensive progressive tax rate and adopts the complicated imputation and deductions law. To suggest a change to adopt the single tax rate to separate and levy taxes, in order to reduce and twist the result and simplify the tax homework. (2) The proposed feasibility study camp of the territorial doctrine adopted tax reform, and taking into account OECD country practices, the establishment of comprehensive antitransnational tax regulations. (3) To review the non-neutrality of the tax measures to allow LIFO-recognized costs, to extend value-added sales tax and to abolish excise and lower income earners’ pay taxes. (4) Taking into account competitiveness, adjust the corporate tax and VAT tax rates of the tax adjustment review. (i) VAT belongs to the tax system of neutrality, and the tax rate of our country is far lower than those of the OECD countries. The rate may be raised to inject financial resources for timely review and reform of the tax system as a supporting measure. (ii) The corporate tax rate is low and concludes various taxes favorably. Suggestions to propose examining the real burden of taxation of enterprises overall, and do it for the supplementary measure of the tax system reform.