數字經濟環境下稅基侵蝕與利潤轉移的應對方案－－建立在信息技術基礎上的預提稅方案

An Approach for Addressing Base Erosion Profit Shifting in the Context of Digital Economy: The Withholding Tax Approach Based on Communication and Information Technology

經合組織在應對稅基侵蝕與利潤轉移（BEPS）第１項行動計畫的最終報告中建議的微調改革方案，難以有效抑制數字經濟誘發的BEPS國際避稅氾濫。針對垮境在線數字化交易誘發的BEPS問題，本文建議應採用一種以電腦稅收遵從軟件支援的預提稅應對方案。這種預提稅應對方案符合國際稅收公平、稅收中性和效率的原則要求，且具有實際可行性，能夠有效扼制數字經濟誘發的國際避稅問題，實現垮境在線數字化交易的國際稅收權益的公平合理分配。 The fine adjustment approach recommended by OECD in its final report of Action 1 of BEPS Program is difficult to effectively regulate the overflow of international tax-avoidance induced by digital economy. To solve the BEPS issues arising from cross-border online digital transactions, this article proposes a withholding tax approach supported by a tax compliance software. The withholding tax approach conforms to the requirements of international tax fairness and tax neutrality as well as the taxation efficiency principle, it has real feasibility and may choke international tax avoidance induced by digital economy effectively and realize a fair and reasonable distribution of international tax rights with respect of cross-border online digital transactions.

The fine adjustment approach recommended by OECD in its final report of Action 1 of BEPS Program is difficult to effectively regulate the overflow of international tax-avoidance induced by digital economy. To solve the BEPS issues arising from cross-border online digital transactions, this article proposes a withholding tax approach supported by a tax compliance software. The withholding tax approach conforms to the requirements of international tax fairness and tax neutrality as well as the taxation efficiency principle, it has real feasibility and may choke international tax avoidance induced by digital economy effectively and realize a fair and reasonable distribution of international tax rights with respect of cross-border online digital transactions.