税收筹划 外文文献
企业增值税纳税筹划外文文献翻译最新
外文文献翻译:原文+译文原文The research of corporate V AT planningPhillips J DAbstractEnterprise tax planning is very necessity. But most tax planning of enterprise is so difficult, the manager normally feel do not know how to start it. This is mainly because when doing tax planning personnel breadth and depth of thinking is limited. In fact, in view of the enterprise a certain business, as long as the tax personnel to all business related tax law research understand the relevant rules and regulations are in place, so companies when doing tax planning should be no problem. For example and to increase "camp" the tax planning, the categories of taxes that must be considered including the business tax and value-added tax, the relevant expenses such as urban maintenance and construction tax and educational expenses to add. Of course, the enterprise can not only consider when do tax planning; a business enterprise's business is very broad, so when doing tax planning to overall consideration. Keywords: value-added tax; the individual income tax; Tax rate; Tax planning1 IntroductionEnterprises between the increasingly fierce markets competitions, enterprises want to gain share in the market, a place, you must adapt to the evolution of natural law, has the stronger than other enterprise competitive power, and this kind of competition power depend mainly on market segment and reduce the cost. Undoubtedly tax is an important part in enterprise cost, the main body of enterprise tax include value added tax, income tax, business tax, consumption tax, etc., and occupy the largest proportion of is value added tax, accounting earnings and the realization of the goal of the enterprise plays an important significance. Because different countries have different social and economic development to its policy orientation, so differences exist in different countries and different industries, the tax policy and accounting system for the choice of accounting methods more flexible, which provides a choice of V AT tax conditions and space? The V AT tax planning forenterprise attention, recognition and more and more attention. Tax planning in gradually improve, already have a systematic and market characteristics. And the development of society, market economy unceasing prosperity, has prompted the company constantly innovate oneself production mode, operation concept, management style, etc.For the survival and development to adapt to market competition, enterprises will use every possible method to increase the interest, as far as possible to reduce the amount of unnecessary consumption, so how to reduce the tax burden is the problem that managers must consider carefully. Modern enterprises in pursuit of the enterprise value maximization as the goal development relative to evade taxes and tax risk of higher taxes, so business leaders can choose to reduce the tax, tax planning the implementation of reasonable overall planning can make the company a huge income.2 V AT descriptionsValue-added tax is the enterprise product in the process of production, circulation, and the value added part of the labor service or value added, the additional levy taxes. No matter which country, regardless of its power, as long as it is a value-added tax, to enact specific regulations on value-added tax. Generally divided into three kinds, one is the production, the second is income-producing, and three is a consumer.2.1 Production-type V ATProduction-oriented V AT has relationship with the company's production, it is well known that a mature enterprise need fixed plant, equipment, products used in the production of raw materials, transportation, fuel, fixed assets, product sales and production of profit, the sales revenue minus the production and operation of the balance of the raw materials, fuel and power as prescribed by the state of appreciation, this also is the basis of the production V AT, in principle, value added tax is not to be bought and depreciation of fixed assets, value added tax is a period of time limit, the tax basis by the tax unit labor balance, and used in the production of loss and the balance of sales revenue, which belongs to the category of value-added tax, fixed assets depreciation is used in the process of transfer value, is also a part of value-added tax levy, which is called double taxation. Based on this, with a largeenterprise as an example, the higher its value of fixed assets, to the payment of taxes, the more because of the wear and depreciation is not deducted, in the process of production is also repeat pay; This part of income is almost equivalent to the gross national product, so called the production-oriented V AT, it includes the rent, wages, profits, interest and depreciation of fixed assets, etc.2.2 Consumption-type V ATIn a word, it is not including the current depreciation of fixed assets and net income tax, including the taxpayers' wages, profits, interest, and rent, etc., in terms of a country, relative to the production-oriented V AT is gross national product, net national product. It is deducted for the production of all the value of fixed assets and depreciation forehead, purchased raw materials and labor value of net income, after is the income of the enterprise production and sales, including spending part, such as wages, so called income-producing V AT.2.2 Income-type V ATDue to the use of standard, advanced, has a legal basis, is engaged in the tax accounting practical operation is simple, popular among countries in the world. A category is a one-off deducted for production and operation of the fixed assets value and the value of the purchase raw materials in the tax, that is to say, the taxpayer’s tax products for production and operation, and are not all the outsourcing material to this category. Fixed assets has been imposed production V AT, of course, but the operator is used as a purchase of fixed assets, its tax gold when the purchase has been deducted, relatively, this part of the goods as fixed assets, there would be no tax, as the nature of the V AT collection does not include other production of raw materials, only including the management of all sales of consumer goods. Consumer is a use of special V AT invoices for V AT tax withholding of taxes, occupies a certain advantage, due to its treatment scope strictly enforced, standard, has certain advancement, and are applicable in many countries.3 The characteristics of added-value tax3.1 Wide taxEnterprise engaged in the work of production and sales for the main V ATcollection objects, individuals engaged in business also in the collection and processing, such as small restaurants, small articles of daily use operators, etc., are widely applicable to all kinds of ownership enterprises and individuals, embodies the fairness of the tax system.3.2 Indirect taxV AT calculation is not directly to value multiplied by the applicable tax rate to calculate the tax payable, but by buried output tax and tax balance to determine the tax payable. Although V AT is the value-added tax on appreciation forehead that increases the value or goods, but in the actual execution process, due to the added value of goods or services or goods value is a difficult to calculate the data, so the V AT only by way of indirect tax. Indirect tax measures increased the difficulty of the value-added tax calculation and collection management.3.3 Additional taxGoods have to be sold by pricing, V AT tax refers to the outside valence is not including commodity tax on the original price. When selling goods, should will receive all the money was divided into excluding V AT price sales and value added tax, and on the special V AT invoices to the tomb-sweeping day, respectively, in this way, the V AT on revenues, costs and profits will not occur, also need not collect V AT included in the income statement. Although it is important to note that the V AT is outside valence tax, but the sales direction while receiving payment from buyers tend to be merged charge, through a certain calculation formula of a sales tax were decomposed into will not sales tax and value-added tax, and fill in the V AT special invoice respectively, rather than in the place where has to determine the price of the total sales of value-added tax calculated separately again.3.4 Special invoiceV AT is absolute and levy, in order to avoid only partially and the phenomenon of double taxation, must carry on the effective control of each link, implement V AT is unified, special invoices, and according to the stated on the invoice amount to impose a tax deduction method, this is the main method for effective control. Countries introduced related management way, strengthen the management of the specialinvoice, the rules on the scope of the use of special V AT invoices, the invoice issued the purpose to make clear a regulation, also completed, enterprises have an obligation to give the buyer special invoices for value-added tax, and to do specialized tickets, taxable services shall be paid not, except duty-free goods also. All invoices shall be protected by law. Special invoices for specific use measures enterprises in strict accordance with the provisions of the calculation, on the basis of the in and out of balance of the current period by the enterprise, both reasonable and legitimate, is the duty of the taxpayer. Thus, to strengthen the taxpayer over the use of special V AT invoices highlighted the value-added tax levy management effect.4 The V AT tax planningV AT tax planning is the content of the enterprise according to their own economic activities, on the premise of not illegal, V AT tax matters to the enterprise to seek planning V AT tax minimization of planning and arrangement. It has the following features:4.1The result of V AT tax planningCity building duty and educational expenses to add belongs to attach tax, as the value-added tax falls. But at the same time, if the two tax drops, can lead to enterprise's total profits, so the enterprise income tax will rise. So, the result of the tax planning may be related to some deviation from the ultimate goal of enterprises to reduce tax burden.4.2 V AT special invoices for value-added tax planningInvoice buckle tax law is a common way to calculate the V AT payable taxes, so special invoices for value-added tax management is the key content of value added tax management. Enterprise product sales directly affected by the special invoices for value-added tax, can open will promote the further development of the enterprise; on the other hand, will affect the size of the enterprise. So, V AT tax planning is the need of the development of the enterprise, therefore in the process of V AT tax planning, to consider the problem of special V AT invoices to the enterprise development prospects.4.3 The planning of the tax burden onKnown to value added tax is a turnover tax, also proves that it is the identity ofthe indirect tax, from the nature of the object defined, flow from it this is the flow of goods, the circulation tax included in commodity prices, determines the turnover does not open automatically. And tax excluded in price, taxes are independent in accounting book, looks like has nothing to do with the price, but it is also part of the purchase price, income tax is directly understand hang, V AT tax on hidden is indirectly. Because of V AT qualitative, its scope covers almost all walks of life, can say all the goods in the column, but for taxpayers, because taxes will rise in price is not reasonable publicly, will be opposed by the consumers. So, the taxpayer can only secretly push up commodity prices, will tax include in the price, do not attract the attention of consumers, easy will be passed on to the purchaser, tax and consumers don't know, so don't oppose.文献出处：Phillips J D. The research of corporate V AT planning [J]. The Accounting Review, 2016, 1(3): 40-52.译文企业增值税纳税筹划研究Phillips J D摘要企业进行纳税筹划是非常有必要性的。
291.E关于增值税的税收筹划认识与思考 外文原文
Value-Added Taxes in Developing and Transitional Countries:Lessons and QuestionsRichard M. BirdUniversity of Toronto - Joseph L. Rotman School of ManagementAbstract：The value-added tax has, in recent decades, become the most important single tax in most developing and transitional economies. This paper reviews some problems that have emerged as important as more experience has been gained with how VATs really work in many such countries and suggests some lines of research that need to be explored further to overcome those problems.1. IntroductionFew fiscal issues are more important in developing and transitional economies (DTE) than the value-added tax (V AT). Over the last few decades, V AT has swept the world. The principal reasons for the rapid spread of this form of taxation were, first, the early adoption of this form of taxation in the European Union (EU) and, second, the key role played in spreading the word to DTE by the International Monetary Fund (IMF) in particular and by international agencies and advisors more generally. The success of V AT in the EU showed that V AT worked. The consistent support and advocacy of this form of taxation by the IMF and others in a variety of countries, first in Latin America, and then around the world, encouraged and facilitated the adoption of V AT by countries with much less developed economic and administrative structures than those in the original EU member states. At the same time, for various reasons of their own, all the non-EU countries of the OECD apart from the United States have also, one by one, introduced V ATs, most recently Australia in 2000.Of course, to a certain extent, as the background paper (ITD, 2005) observes, the V AT label covers a variety of taxes in different countries. Countries that belong to the EU have necessarily all adopted the same model of V AT, essentially as laid out by the Sixth Directive of 1977, although some important differences remain between V ATs in EU member states (Mathias, 2004). Other countries influenced by the EU such as the recent and prospective ‘accession’ countries of central and eastern Europe have als o largely followed this model. Elsewhere in the world, however, while the influence of the EU model (and some member-state variants) is clear in, for example, some former colonies of EU member states, other models have been developed and adopted, notably in New Zealand and Japan. Equally importantly, the IMF’s Fiscal Affairs Department, the leading ‘change agent’ in this respec t for in much of the world has over time evolved what is essentially its own ‘model’ of an appro priate V AT for DTE, as set out initially, for instance, in Tait (1988, 1991) and most recently in Ebrill et al. (2001). While V AT countries have introduced many local variations into whatever b asic ‘model’ they mayhave started from1,as Victor Thuronyi (2003, p.312) has recently noted, “ while there are differences in V AT from one country to another, compared with the income tax V AT laws are remarkably similar.”When DTE have a V AT, it is invariably among the most important sources of government revenue. Indeed, anyway one cares to look at it V AT has clearly been an enormous success. Not only has it swept the world almost clear of contending general sales taxes but in many DTE it dominates the income tax as the mainstay of national finances. No previous fiscal innovation has been adopted in such a wide variety of countries so rapidly.Not all is sunshine in V ATland, however. Clouds of varying sizes and shapes seem to be looming on the horizon in all V AT countries but perhaps particularly in DTE that have become increasingly dependent on V AT and hence more vulnerable to potential problems. Some of these problems have always been inherent in the structure and operation of V ATs but are exacerbated by the increased fiscal weight being placed on the many DTE under pressure for new fiscal revenues for example to offset revenue losses from tariff reductions needed to accord with WTO requirements. It is thus perhaps time for a new look at the role of V AT in DTE.Specifically, are the V ATs now in place in most DTE as good as they could be in economic, equity, and administrative terms? Must ‘good’ V ATs i n such countries always follow the same pattern? Must every DTE have a V AT? Can all DTE administer a V AT sufficiently well to make the introduction of the tax worthwhile? Is a V AT always the best way to respond to the revenue problems arising from trade liberalization? Can V ATs be adapted to cope with the rising demands in some countries, especially federal countries, for more access to revenues by local and regional governments? Can they deal with such new problems as those arising fromchanges in business practices with financial innovations and digital commerce? The answers to such questions are not only critical to the fiscal stability of many DTE but also to their economic growth and development. Are the V ATs already in place in many DTE the efficient, simple, revenue-raisers some claim? Or, as others argue, are they so inequitable as to exacerbate social and political tensions? Does V AT provide a way to tap the informal sector or does it instead tend to expand that sector?No brief paper can answer such complex questions, of course, so the objective of this paper is considerably more modest. Taking the background paper prepared for this conference (ITD, 2005) as its starting point, the aim of this paper is simply to provide a few additional reflections on some lessons that seem to emerge from experience to date with V AT in DTE -countries in which, for the most part, tax reality is much more dominated by administrative capacity on one hand and political necessity on the other than in the European home of so much V AT experience and thinking. There is indeed much room and need for sharing experiences between developed countries and DTE, but there are also some important differences that need to be explicitly taken into 1For a small sample of early country experiences, see e.g. Gillis (1990), OEA (1993), Yoingco and Guevara (1988), and OECD (1998), and for a sample of the discussion in an important current case, that of India, see e.g. Shome (1997), Chelliah (2001), and Empowered Committee (2005).account when doing so. To paraphrase the conclusions of the late Jean Jacques Laffont (2004) in a recent survey of public utility regulation in DTE, not only do we as yet have surprisingly little solid empirical knowledge of some critical factors but the relevant economic theory also remains rather sketchy and we know even less about the relevant political economy context. For the most part, this paper simply attempts to flesh out these observations in a little more detail with respect to V AT in DTE. In doing so, it should perhaps be noted that although the points made are stated in general terms for the most part they are inevitably shaped by the author’s limited personal experience with various aspect of V ATs in a number of DTE over the years. In a sense, however, this is perhaps not a limitation since it is precisely through closer analysis of, and reflection on, the experience of such case studies that we can best discern the real challenges facing V AT in DTE and the questions that most need further attention. Such at least, is the approach taken here.22. Lessons from ExperienceAt the risk of repeating some of the many good and sensible things said in the background paper, this section discusses briefly five major lessons that emerge from the extensive experience with introducing and implementing V ATs in DTE. First, and most importantly, as the background paper says, V AT works. Despite some recent criticisms by reputable analysts, for the most part it remains true that, if a country needs or wants a general sales tax, it is well advised to have a V AT. Secondly, nonetheless V AT does not always work well in many DTE, principally because some are simply not ready f or ‘self-assessment’. Thirdly, what this suggests for tax design is what may be called ‘the NOSFA principle’ - No One Size Fits All - although it may be that several ‘sizes’ (patterns) of V AT may prove suitable for different groups of countries in similar circumstances. Fourthly, the major lesson for tax administration that experience in DTE suggests is that the oft-c ited ’18-24 months’ needed for successful V AT implementation vastly understates the nature and time scale of the task in many countries. Many DTE cannot be simply, as it were, ‘given’ a good V AT administration: they need to ‘grow’ it themselves and the process may take a long time in some cases. Finally, since tax policy is always about politics as much or more than it is about tax design and administration, ) once said in a discussion of OECD countries, tax policy “…is about trade-offs, not truths.”To some extent at least, the future of V AT in DTE lies in much closer understanding of the critical politicaleconomy dimension of V AT policy and administration.2.1 V AT WorksAs the background paper shows, V AT is by no means n ecessarily the ‘money machine’ that it has sometimes been called. The effects on revenue of introducing a V AT in particular contexts remains a matter open to interpretation and question, as recently underlined by some who have questioned the capability of V AT to replace 2In contrast to the disclaimer in the background paper, it should perhaps be explicitly noted that, while the author has learned a great deal about these topics from the staff of the World Bank, the IMF, and the OECD and is in addition grateful to Pierre-Pascal Gendron for helpful comments, he alone is solely responsible for all views expressed in this paper.revenues from trade liberalization in some DTE (e.g. Rajaraman, 2004). While it is true that there may indeed be a somewhat stronger case for retaining some taxation on international trade on revenue grounds than has been conventionally asserted, this case rests less on defects of V AT as such than on the assumed relative inefficiency of V AT administration compared to border tax administration (see also section 2.4). If a V AT can be administered adequately, the conventional conclusion that it offers the best way for a country to make up revenue losses from trade liberalization holds, though perhaps in less sweeping terms than originally argued3.Indeed, the equally conventional conclusion that a V AT is the most economically desirable and administratively effective way in which to collect a given share of national income through a general consumption tax also holds -provided, again, that the capacity exists to administer VAT adequately. When a country introduces a V AT, whether to replace another form of general sales tax or as a new tax, there need not necessarily be an aggregate increase in revenues (either from consumption taxes or in general).As a rule, however, the economic cost of collecting revenues will decline, thus making society better off. Similarly, as with any tax, although increasing the rate of an existing V AT rates will neither necessarily increase revenues proportionately nor be costless, it may nonetheless be the economically most sensible way to expand revenue shares in DTE, if that is the policy goal.2.2 But It Does Not Always WorkMore generally, as hinted earlier, what is really at issue in such countries is not so much such specific problems -- all of which may in principle easily be corrected if desired -- but rather the fundamental question of whether they are really ready for the ‘self-assessment’ approach that the background paper properly asserts is how a ‘good’ V AT works. If a country is not ready in this regard, should if have a V AT at all? And, if it does (as many already do), is the best V AT for it always the same as the ‘model’ implicitly set out as a standard in most of the literature? The question is discussed further in the next two sections.2.3. Tax Design: The NOSFA PrincipleA second possibly rewarding approach to explore would be to recast the familiar (if implicit) ‘decision-tree’ approach to V AT by setting out in more detail the i mplications of different nodal decisions (e.g. zero-rating) for other design aspects, then working out the optimal sequence of such decisions for particular countries (or groups of countries), and finally assessing how dependent the ‘rightness’ of particul ar decisions is with respect to different characteristics of the environment within which the V AT is expected to function. While of course many elements of such an approach are to be found in the literature (e.g. Ebrill, 2001), as yet little has been done to set out the relevant decision-points and their interdependence in a systematic fashion or to quantify them in any meaningful way, although the interesting recent work on V AT thresholds (Keen and Mintz, 2003) is a good first step in this direction. Many more such steps are needed.2.4. Tax Administration: Growing into a Good VAT3On this, compare the rigorous analysis in Keen and Ligthart (2002) with the equally rigorous, but different, analysis in Keen and Ligthart (2004).Secondly, as with respect to tax design, more thought seems needed with respect to what one really has to know about a country in order to devise the ‘right’ implementation schedule for its particular circumstances. What matters most and in what ways? Is it the size distribution of the potential tax base? Or the relative importance of ‘key’ base components (such as imports and excise goods) and the degree of administrative control that can realistically be expect with respect to those components? Or the level of accounting skills in the potential taxpayer population? Or the detailed industry-by-industry flow of ‘V ATable’ items between different sectors and different sized firms? Or the capacity of tax officials to administer an accounts- based tax and in particular attention to audit such a tax? Or, perhaps most fundamentally, the degree of existing ‘trust’ between officials and taxpayers and how quickly (and in what ways) that trust can be built up sufficiently to support a self-assessment system? Or is it all of the forgoing and more? Whatever one’s answers to such questions, what seems clear is that one cannot expect success simply by transferring experience from very different developed country settings to DTE with fragmented economies, large informal sectors, low tax morale, rampant evasion, and total distrust between tax administrators and taxpayers. The research agenda with respect to V AT administration in DTE is thus even larger and probably more important than that with respect to V AT design in such countries.2.5. Tax Policy is an Art, Not a ScienceIn the end, what V AT looks like and how it performs in any country inevitably reflects political factors and calculations as much or more than economic and administrative considerations. As a rule, of course, the critical political dimension of the policy process must simply be accepted as given by those directly concerned with tax design and implementation. Nonetheless, it is obviously desirable that they are as fully aware as possible of the manner in which such factors may impact on, and are in turn affected by, such central elements of V AT design and implementation as exemptions (see section 3.2 below).To be forewarned that a particular sector is politically ‘untouchable’ may, for instance, enab le policy designers to be able to work around the problem in a way that does less damage to the tax as a whole than might otherwise be the case4. Somewhat curiously, however, despite the proliferation of real world examples available for study, few careful ‘political economy’studies of V AT implementation appear to have been done in DTE as yet. As such studies begin to appear, they will in all likelihood often suggest still further questions calling for still more scientific (empirical and theoretical) research that may, in the long run, provide more useful advice than can yet be offered to those engaged in the precarious art of policy design and implementation in DTE.4A common joke among development economists years ago was along the following lines: “What difference would it make to development policy in country X if all the political scientists in the wor ld disappeared?” The expected answer, of course, was “No difference at all.” While no doubt serving its intende d purpose of making economists feel perhaps a bit more useful (at least in relative terms), this joke is very wrong indeed. As we have begun to understand with the recent upsurge of the political economy literature, few things matter more for better policy design and implementation in any country than deeper understanding of how politics works in that country.3. Other IssuesMany questions have already been raised about V AT in DTE, and some possible directions in which to search for answers have been tentatively suggested. In this part of the paper, five issues are singled out for a bit more discussion. Section 3.1 raises a prosaic but surprisingly important question: do V AT systems generate the information needed both for sound analysis and good management? Section 3.2 returns to the issue of exemptions mentioned in section 2.2 above, placing it in the more general context of the equity of V AT in the circumstances of many DTE. Section 3.3 focuses on some aspects of the surprisingly controversial questions related to V AT and small business, and section 3.4 continues downward, as it were, into the realm of the ‘shadow’ economy and asks how effective V AT can be in DTE in which such activities constitute a critical sector of the economy. Finally, section 3.5 raises the question of how, if V AT already faces as many problems as discussed here in many DTE, it can possibly cope with such changes as those associated with the looming rise of electronic commerce around the world.3.1. Missing DataOf course, such comments may be applied to any tax. Two features make them especially applicable to V AT, however. In the first place, one unfortunate consequence of the adoption of V AT in replacement of other indirect taxes in many DTE has been the virtual disappearance of any information on the composition of the effective base of consumption taxation. Most studies dealing with this important question infer the tax base indirectly from national income accounts or survey data5.Two simple examples of matters important to understanding how V AT really works in DTE that are amazingly difficult to discover in many countries are the real importance of imports in the V AT base and the importance of excise commodities in that base. Similar data gaps make it difficult in many countries to estimate the likely revenue consequences of base and rate changes in V AT. All these problems are in principle unnecessary, since all the needed information is necessarily generated in the process of administering V AT. But almost never are such data available in a usable form, let alone used.Secondly, V AT is the only tax that involves the government not only in collecting substantial money from the private sector but also in paying a good deal of it back to them in the form of input tax credits. Since any V AT invoice constitutes a potential claim on the treasury, and falsifying such claims is perhaps the most common form of V AT fraud, it is critical from an administrative perspective to have a detailed knowledge of the ‘normal’ or ‘expected’ pattern of credits and liabilities for firms in all the different lines of business subject to V AT. Again, however, although the normal operation of an invoice-credit V AT generates such information, itt is striking how seldom such data are either collected in usable form or used (e.g. for devising a risk management strategy). Perhaps even more surprising is that this whole question has apparently not as yet 5For an interesting recent example, though still a rather simple one, of the information that can be drawn from VAT revenue data about the tax base for EU member states, see Mathis (2004).received much attention from the international community of V AT experts. It should.3.2. Equity IssuesA final point that deserves mention with respect to V AT and equity in DTE is the importance of the shadow economy. Many DTE have a large economic sector that is effectively not subject to direct taxation. This reality clearly should affect how one assesses the effects of different fiscal instruments on equity. It is not at all impossible, for instance, that in some cases even a uniform broad-based V AT may be more progressive than more nominally progressive taxes (such as the personal income tax) that in practice burden only a limited group of wage-earners.The question of V AT and the shadow economy is discussed further in section 3.4 below.3.3. Small ProblemsA quite different approach to the perceived and real problems of dealing with small taxpayers is the so-called ‘V AT withholding’ found in some c ountries (and mentioned in the background paper). In effect, this practice assumes that V AT will not be reported properly by small firms and hence requires those selling to such firms to ‘withhold’ an additional V AT on such sales to make up for the V AT those firms are supposed to collect (but are expected not to remit even if they do collect) on their own sales. Such ‘dual pric e’ systems are usually imposed at arbitrary rates and make no logical or administrative sense; nonetheless, they are sufficiently common, and are suggested sufficiently often in countries in which they do not now exist, to call for closer examination than they seem so far to have received. For example, what is the best way to determine the appropriate ‘withholding’ rates (essentially p resumptive taxes) in different circumstances? Are such ‘withheld’ V AT ever credited agains t V AT actually reported by the firms from whom they have been withheld? What is the net effect on revenue of such systems?Finally, most discussion of the appropriate treatment of small firms appears to assume that there is no difficulty in telling which firms are small. As with giraffes, it appears that one is supposed to know one when one sees one. As discussed in the next section, however, this assumption is probably wrong in many DTE.3.4. Chasing ShadowsOne reason such regimes have been created in some DTE is because the normal tax regime is considered (by those who put it in place, presumably) to be too complex and often also too harshly applied and perhaps unduly prone to corruption, extortion, and harassment. Insulating selected (sometimes self-selected) taxpayers from such problems does not make the problems disappear. On the contrary, it is likely to make them more difficult to deal with, both by complicating tax administration as a whole and by reducing political pressure to fix the basic problems with tax administration. Taking people out of the V AT system is a particularly bad idea since information is the lifeblood of an effective V AT administration. Every effort should be made to avoid breaking the information chain, rather than encouraging firms to do so, as simplified systems in effect do.3.5. Changing with the TimesBy the time this last problem become significant for most DTE, however, perhaps some better way of dealing with it may have been discovered. For the next few years, probably the main advice one should give to DTE with respect to V AT and electronic commerce, as with respect to such other ‘frontier’ issues as the treatment of the f inancial sector and the public sector, is simply not to worry much about such esoterica but rather to concentrate on the difficult task of first getting an appropriate V AT into place and then running it effectively. The basic question in many DTE is not how to deal with ‘new’ issues but rather how one can make a tax like V AT, which essentially depends on self-assessment, function adequately in countries that in many instances do not appear to have satisfied the necessary preconditions for a self-assessment system. The answer, as suggested earlier, may be to spend more time and effort trying to determine what kind of less-than-perfect V AT will function best in such countries and then working out in more detail the best way in which they can move over time from such unsatisfactory (though necessary) initial positions to a good V AT. Good answers along these lines can in all likelihood only really be determined in the context of close study of particular countries.4. A conclusionTo sum up, V AT is of course not ‘the answer’ to the fiscal problems of DTE. Despite the many problems and questions raised above, however, some form of V AT almost certainly constitutes a critical ingredient in such an answer. Even the best possible V AT will not solve all the problems of DTE: the V AT they have may not always work well; in some instances it could be designed better to fit the context of the country; in many instances, it could certainly be administered better, even in the face of adverse political and capacity factors. Nonetheless, so long as a general consumption tax makes sense as a key part of a country’s fiscal system, as is surely true in most DTE, V AT remains the best available fiscal instrument we have. According to the background paper, 136 countries now have a V AT of some sort. Information from the IBFD (Annacondia and van der Corput, 2003) suggests that there remain at least 63 countries that do not have V ATs, 41 of which now have some other form of general consumption tax and 23 of which appear to have thus far been able to avoid facing the problem. When the next Global conference on V AT takes place, it is thus a safe prediction that yet more countries will have V ATs. It remains to be seen to what extent the various issues raised above will have been either dispelled or more adequately dealt with by that time. ReferencesAhmad, Ehtisham and Nicholas Stern (1987) “Alternative Sources of Government Revenue: Illustrations from India, 1979-80,” in David Newbery and Nicholas Stern, eds, The Theory of Taxation for Developing Countries (New York: Published for the World Bank by Oxford University Press).Annacondia, Fabiola and Walter van der Corput (2003) “Overview of General Turnover Taxes and Tax Rates,” V AT Monitor, March/April, pp. 2-12.Auriol, Emmanuelle and Michael Warlters (2004) “Taxation Base in Developing Countries,” ARQADE, Toulouse, July.Baer, Katherine, Olivier P. Benon and Juan A. Toro Rivera (2002) Improving Large Taxpayers’ Compliance: A Review of Country Experience. Occasional Paper 215. (Washington: International Monetary Fund).Bird, Richard M. and Sall y Wallace (2004) “Is It Really So Ha rd to Tax the Hard-to-Tax? The Context and Role of Presumptive Taxes,” in James Alm, Jo rge Martinez-Vazquez and Sally Wallace, eds. Taxing the Hard-to-Tax: Lessons from Theory and Practice (Amsterdam: Elsevier).Chelliah, Raja J. et al. (2001) Primer on Value Added Tax (New Delhi: Har-Anand Publications Pvt. Ltd.)Cnossen, Sijbren (2004) “V AT in South Africa: What Kind of Rate Structure?” V AT Monitor, January/February, 19-24.De Ferranti, David et al. (2004) Inequality in Latin America: Breaking with History? World Bank Latin American and Caribbean Studies (Washington: The World Bank). Desai, Mihir A. and James R. Hines, Jr. (2002) “Value-Added Taxes and International Trade: The Evidence,” University of Michigan, Novem ber.Devarajan, Shantayanan and Ritva Reinikka (2003) “Making Services Work for Poor People,” Finance and Development, September, 48-51.Ebrill, Liam, et al. (2001) The Modern V AT (Washington: International Monetary Fund).Empowered Committee of State Finance Ministers (2005) A White Paper on State-Level Value Added Tax. New Delhi, January.Emran, M. Shahe and Joseph E. Stiglitz (2002) “On Selective Indirect Tax Reform in Developing Countries,” Stanford University, June.Engelschalk, Michael (2004) “C reating a Favorable Tax Environment for Small Business,” in James Alm, Jorge Martinez-Vazquez and Sally Wallace, eds. Taxing the Hard-to-Tax: Lessons from Theory and Practice (Amsterdam: Elsevier).Gerhanxi, Klarita (2004) “The Informal Sector in Develope d and Less Developed Countries: A Survey,” Public Choice, 120: 267-300.Gillis, Malcolm, Carl S. Shoup, and Gerardo P. Sicat, eds. (1990) Value Added Taxation in Developing Countries. A World Bank Symposium (Washington: World Bank). Hines, James R., Jr. (2004) “Might Fundamental Tax Reform Increase Criminal Activity?” Economica, 71: 483-92.International Tax Dialogue (ITD) The Value Added Tax: Experiences and Issues,” Prepared for the ITD Conference on the V AT, Rome, March 15-16, 2005.Keen, Michael and Jenny E. Ligthart (2002) “Coordinating Tariff Reductions and Domestic Tax Reform,” Journal of International Economics, 56 (2): 407-25.Keen, Michael and Jenny E. Ligthart (2004) “Coordinating Tariff Reduction and Domest Tax Reform under Imperfect Competi tion,” Unpublished paper, Washington, May.Keen, Michael and Jack Mintz (2003) “The Optimal Threshold for a Value-added Tax,” Journal of Public Economics, 88: 559-76.Laffont, Jean-Jacques (2004) “Management of Public Utilities in China,” Annals of Economics and Finance, 5: 185-210.Mathis, Alexandre (2004) “V AT Indicators,” Working Paper No. 2/2004,。
纳税筹划文献综述及外文文献资料
纳税筹划文献综述及外文文献资料本文档包括改专题的：外文文献、文献综述一、外文文献文献信息标题：Effect of Tax Planning on Firms Market Performance: Evidence from Listed Firms in Ghana 作者：Kawor, Seyram; Kportorgbi, Holy Kwabla期刊：International Journal of Economics and Finance第6卷，第3期，页码：162-168，2014年Effect of Tax Planning on Firms Market Performance: Evidence from Listed Firms in GhanaKawor, Seyram; Kportorgbi, Holy KwablaAbstractThe study sought to ascertain the level of tax planning of firms and to explore the relationship between tax planning and firms' market performance. The study used 22 non-financial companies listed on the Ghana Stock Exchange over a twelve year period from 2000. The longitudinal correlative designed was used. The results indicate that that firms' tendency to engage in intensive tax planning activities reduces when tax authorities maintain low corporate income tax rates. Secondly, tax planning has a neutral influence on firms' performance. This finding challenges the general perception that every cedi of tax savings from tax planning reflect in the pocket of investors. It is concluded that investors must institute systems to ensure tax planning benefits reflect significantly in their pockets.Keywords: Ghana stock exchange, tax planning, market performance, longitudinal correlative design, investors1. IntroductionOver the years and throughout the world, the history of taxation brings out one fact; that taxes are coercive in nature and therefore economic units which are assigned the tax liability never wholly intend to bear the actual tax burden (Commonwealth Association of Tax Administrators (CATA), 2007). Economic units, more specifically, corporate bodies are always adopting ways to minimise, postpone, or avoid entirely, the payment of tax. The attempts by the economic units to reduce, postpone or avoid tax payment can be legal or illegal. The legal means is called tax planning while the illegal means is called tax evasion. The dire consequence of tax evasion makes it an unattractive option for listed companies (Murphy, 2004).The practice of tax planning dates back to 1947 when learned judge Hand, in the case Commissioner v Newman, held that there is nothing sinister in arranging ones affairs so as to keep taxes as low as possible. Hoffman's (1961) tax planning theory supports this argument. According to Hoffman, it is a necessity for firms to understand the prevailing tax laws and apply the laws in a manner that ensures the firms minimise their tax exposure. Hoffman posits that it makes no economic sense to pay more tax than what the law demands. Scholes and Wolfson's (1992) tax planning framework also underscores the need for corporate bodies to engage in tax planning. According to Scholes and Wolfson, a successful company is the one that is properly attuned to its tax environment.International governmental organizations, such as CA TA (2009), suggest that corporate bodies in Ghana, especially the large entities, engage in complex tax planning activities. Research by civil society groups such as Christian Aid (2008), Action Aid (2011), and Dan Watch (2011), confirm this assertions made bythe Domestic Revenue Division. The missing element in the findings is thequantitative expression of the tax planning activities of the firms.The traditional thinking is that firms that derive maximum benefit from tax planning perform better than those that do not plan their taxes (Murphy, 2007). From the empirical perspective, tax planning is positively associated with firms' performance. For instance, Desai and Hines (2002); Chen, Chen, Chen and Shelvin (2010) reported positive association between tax planning savings and firm performance. The argument is that tax represents cost of doing business, and any action that has the potential of minimising tax cost reflects in higher firm performance. This argument presupposes that tax planning cost and risk does not exceed the savings from the planning.Few studies in the UK dispel the traditional relationship between tax planning and firm performance. While admitting that tax planning has a positive association with accounting performance, Desai and Dharmaphala (2007) reported that tax planning has a neutral association with market performance. Indeed Abdul-Wahab (2010) found a negative association between tax planning and firm performance. Kportorgbi (2013) suggested that corporate governance strength plays a mediating factor in the tax planning-firm performance relationship.A study of the effect of tax planning savings on firms' market performance is crucial for all stakeholders in the emerging security markets such as the Ghana stock Exchange. In fact each possible relationship has a unique implication for the players. For instance, a positive association implies that tax planning produces a win-win situation for both management andshareholders (investors). A negative association connotes that tax planning benefits may not eventually trickle to the pocket of the shareholder. Indeed, a negative association may be an indicative of the existence of agency problem, where management is inclined to pursue tax planning to enhance their own lot rather than advancing the interest of the investor. Where a neutral association is established, it will invoke a follow up study on the possible factors that could influence the relationship either positively or negatively. Secondly, the study is necessary to inform tax planning agents and investors on the dynamics of tax planning1.1 Objective of the StudyThe primary objective of this study is to explore the relationship between tax planning savings of firms listed on the Ghana Stock Exchange and firm market performance. The study also seeks to examine the simultaneous influence of other firm specific variables on the tax planning-market performance relationship.1.2 Tax Planning Intensity of Firms in GhanaCommentators on tax behaviour of firms in Ghana paint a picture that suggests that large firms engage in tax planning activities. For instance CATA (2009) posits that Ghana Revenue Authority lost seventy-four million pounds between 2005 and 2007 to the European Union (EU) in tax revenue as a result of tax avoidance by several multinational companies. Murphy (2004) also reported that firms have complex gamut of arsenals to reduce their tax burden. The reports indicate that the tax avoiding mechanism of firms are largely allowed by the tax laws. There are also indications that the firms take advantage of the loopholes in the tax laws to derive unintended tax benefits. Theavenues for tax planning usually revolve around locational reliefs, industry-specific concessions and capital allowance provitions. Others are time variables and entity variables.Most of the reports are not precise in their estimation of the benefits that firms achieve through tax planning. The lack of precision in measuring tax planning intensity is largely attributed to the insufficient reporting of issues of taxation by firms. Aside the mandatory disclosures to tax authorities, firms are reluctant in disclosing much on tax behaviours. This is due to the perceived thin line that exist between tax planning and tax evasion. Listed companies, however, provide provide adequate information necessary to estimate the tax savings of the firms. This is made possible by virtue of the financial reporting guidelines provided by the security exchange commision.2. Review of Related LiteratureThis section is subdivided into theoretical review and empirical review. The theoritical review encapsultes the Hoffman's (1961) tax planning theory. Three main empirical studies are reviewed. They are Desai and Hines (2002), Desai and Dharmaphala (2009) and Abdul-Wahab (2010).2.1 Hoffman's Tax Planning TheoryAccording to Hoffman (1961) tax planning seeks to divert cash, which would ordinarily flow to tax authorities, to the corporate entities. Tax planning activities are desirable to the extent that they reduce taxable income to the barest minimum, without sacrificing accounting income. The theory is premised on the fact that firms tax liability is based on taxable income rather than accounting income. The idea is thus to intensify activities that reduce taxable income but has no indirect relationship on accounting profit. The theory thus recognised a positiveassociation between firm tax planning activity and firm performance.Hoffman (1961) also recognised the role of tax cost in the tax planning activities. The theory thus provided that the positive association between tax planning and corporate performance is on a basic assumption that tax benefits from the tax planning exceed tax cost. The scope of the Hoffman's tax planning theory does not address the dynamics of tax planning and market performance. As capital markets develop and the separation of ownership and control of corporate bodies become well-spread, the need for a comprehensive tax planning theory is imperative. This need is rather addressed through the empirical perspective than through theoretical perspective (Inger, 2012).2.2 Empirical Review and Development of HypothesisDesai and Hines (2002) provide evidence on firm performance and tax planning behaviour of firms. Again, the study investigates the relationship between tightening of tax systems and market value of firms. The study was based on 850 listed US firms. The study sample was purposively selected to reflect the characteristics desired by the researchers. The study was cross sectional and the data relates to year 2000. Correlative-description design was adopted. Simple regression and t-tests were used to establish the relationships. Desai and Hines established that intensive tax planning is associated with higher firm performance. On the other hand, the study reported that tightening of the tax system is positively associated with higher market performance of firms. The findings of Desai and Hines (2002) are similar to that reported by Chen, Chen and Chen (2010). Desai and Dharmapala (2007) provided a comprehensive study that incorporates tax planning, corporate governance andfirm performance. The study used 4,492 observations on 862 firms over the period 1993 to 2001. This panel data was drawn from the Compustat and Execucomp databases, merged with data on institutional ownership of firms from the CDA/Spectrum database. Firms' performance is measured using Tobin's q and governance quality is proxied by the level of institutional ownership. Tax planning is measured by inferring the difference between the income reported to capital markets and tax authorities (the book-tax-gap). Two analysis models were adopted-the OLS model and the IV estimation model. The OLS results shows that the average effect of tax planning on corporate performance is not significantly different from zero. In other words, there is no relationship between tax planning and firm performance. The study howeverreports a positive association between tax planning savings and performance for well-governed firms. Desai and Dharmapala (2007) thus concluded that corporate governance mediates the tax planning-firm performance relationship. The IV estimate shows a higher effect of corporate governance on firm performance.Abdul-Wahab (2010) provides a result that differs from the findings of Desai and Hines (2002), Desai and Dhamarpala (2009), and Chen, Chen, Chen and Shelvin. Abdul-Wahab's (2010) study sought to establish a relationship between tax planning savings of firms and their value. The study simultaneously investigates the moderating influence of corporate governance. Abdul-Wahab's study employed 240 firms listed on the London stock exchange from 2005 to 2007. Tax planning was proxied by the difference between the effective tax rate of the entities and the applicable statutory tax rates. Self-constructed governance indexwas constructed using corporate governance mechanisms. Firms' value was represented by the Tobin's Q. The data was analysed using panel regression analysis model. As a check, the OLS model was also used.The results indicate a negative relationship between firm value and tax planning activities. Abdul-Wahab (2010) explains the relationship with reference to tax planning cost and risk. The study suggested that tax planning cost and risks associated with tax planning have the potential of derailing the benefits that should have accrued to shareholders. The researcher maintains that as tax planning activities increase, the tax costs and risks outweighs the benefits.Due to the diversity of the relationships found between tax planning and firms' market performance, it is right to develop a null hypothesis as:H1: There is an association between tax planning and firms' market performance.It is unreasonable to suggest that tax planning is the only determinants of firm performance. Baring the existence of multicollinearity between (among) the explanatory variables, sales growth, financial leverage, firm size and age of the firms will be introduced into the regression models. Several studies, including Desai and Hines (2002), Desai and Dharmaphala (2007), Abdul-Wahab (2010) reported positive association between firm performance and sales growth, firm size and financial leverage. It is thus clear to develop the null hypothesis that:H2: Firm performance and sales growth and firm size are positively associated.Firms' age, according to Desai and Dharmapala (2007) and Abdul-Wahab (2010) has a negative association with marketperformance of firms. This gives rise to the third null hypothesis that:H3: Firms age and financial leverage are negatively associated with firms' market performance. 3. Methodology Longitudinal correlative design is adopted for the study. Longitudinal design is essential if the same research entities sampled in a cross section are then re-sampled at different times (Creswell, 2009; De Vaus, 2001). According to the authors, the design helps overcome limitations associated with the "snap shot" approach of cross sectional designs.The study population comprises all non-financial firms listed on the Ghana stock exchange. As of June 2013, twenty-three (23) out of thirty-five (35) firms listed on the Ghana Stock Exchange were non-financial companies. Financial companies are excluded from the population. Previous researchers posit that the financial sector is a highly regulated sector and as such regulations blur the relationship that exist among the variables to be studied (O'Hamon & Taylor, 2007; Desai & Dharmapala, 2009; Abdul-Wahab, 2010).The study uses a panel data for twelve-year period, from 2000 to 2011. Data for the study is collected from the database of the Ghana Stock Exchange. Panel regression model is adopted fordata analysis and the Ordinary least square (OLS) been the method of regression.The regression model is summarized as:(1)α = (alpha) shows the constant affecting net profit margin on corporate tax.Tobin's q (market performance) = (market capitalization ofentity) ÷ (book va lue of shareholders fund).Tax savings = Statutory tax rate -Effective tax rate.Statutory tax rate = flat rate as mandated by the Ghana Revenue Authority.Effective tax rate = Corporate income tax expense/profit before tax.Sgrowth (sales growth) = (Previous Sales revenue -Current sales revenue) ÷Previous sales revenue.Fsize (firm size) = Natural log of firm's total assets.fLev (Financial leverage ) = Long term debt/shareholders fund.Age (Age of firms) = log(the difference between the year of establishment and years of observation).4. Results and DiscussionFigure 1 and Table 1 presents the descriptive statistics for two key variables, namely tax planning of firms and market performance over the twelve year period.Like the statutory rate, tax savings of firms show a decreasing trend. As tax authorities take steps to reduce the tax burden on firms, the leakages in tax revenue due to firms tax planning activities reduce. From figure 1, the statutory tax rate reduced from about 32% to 25%. Tax savings of firms reduced also from 15% to 8% by 2011. That is to say each percentage point decrease in the statutory rate leads to a corresponding decrease in firms' tax planning savings.The policy implication of this finding is two-fold. Firstly, the notion of increasing tax rate in order to rake in more tax revenue may not hold. As tax rates increased, the motivation of firms to deny the state of revenue through intensified tax planning machinery is enhanced. Secondly, as the tax rate is decreased, thenet benefit of planning tax is derailed. The way forward for tax revenue optimisation is to maintain lower tax rates and drag more firms into the tax net.Table 1 provides the market performance of the firms over the twelve year period.The farther the Tobin's Q is from unity, the better the company performance. From Table 1, all the company groups recorded an average score higher than 1.00. The overall average score is 1.78 (the median represents the average as skewness is negative). The high average market performance by the firms is driven by only the mining sector and the manufacturing companies. All the remaining classes of companies recorded lower than the average score.This finding confirms the observation of business persons in Ghana that business climate in Ghana gives unmatched advantage to the mining sector. The service sector records the lowest market performance. This raises a major concern as the sector is the major contributor to gross domestic product (GDP) in Ghana. Another sector to watch out for is the oil and gas. This sector has the most recent history. It was expected that the high hopes of investors in the sector after the discovery of oil in commercial quantities in Ghana would have positive influence on the performance. It is expected that the sector will be one of the major drivers of firms' market performance in the future.Table 2 provides correlation results on the variables. This result is essential for at least two reasons. Firstly, it shows basic association between the dependent variable (market performance) and theindependent variable. Secondly, it shows if the "so-called" independent variables are indeed independent. In other words, ittests the multicollinearity status of the independent variables. From Table 2, the correlation co-efficient between tax savings and Tobin's Q is 0.112. This is however significant at 0.097. This significant level is compared with the default alpha of 0.05. As rule of thumb, we reject the null hypothesis if the actual significant level is higher than the expected alpha and do not reject if the actual significant is less than the expected alpha. In this instance p-value of 0.097 is greater than the expected alpha of 0.05. The null hypothesis that:H1: There is an association between tax planning and firms' market performance is rejected.The correlation results do not suggest causation but gives an indication of association between the variables. The "no relationship" finding between tax planning and firms' market performance supports the reports of Desai and Dharmapala (2007) but differ from the findings of Desai and Hines (2002) and Abdul-Wahab (2010). The findings suggest that although savings from tax planning reflect in higher profit after tax, it does not necessarily reflect in the pocket of shareholders. This finding ignites studies aimed at uncovering factors that mediate the tax planning-firm performance relationship. Indeed, it might be the reasons behind the works of Desai and Dharmapala (2007), Desai and Dharmapala (2009) and Abdul Wahab (2010).Another finding in table 3 is the relationship between market performance (proxied by tobin's Q) and the firm specific variables. Sales growth and firm size shows positive and significant association with firms' market performance. On the other hand financial leverage and age of the firms shows a negative association with firm performance. The findingsWe do not reject the null hypotheses (H2 and H3) stated asH2: Firm performance and sales growth and firm size are positively associatedH3: Firms age and financial leverage are negatively associated with firms' market performance. Further Table 3 gives an indication that multicollinearity among the independent variables does not exist. The rule of thumb is that if the correlation coefficients between any two of the variables is above 0.50 (either positive or negative), those two variables are multi-correlated and should not be simultaneously included in the regression model. From Table 3, this condition does not exist. The variables can be regressed against the dependent variables.Table 3 shows the regression of Tobin's Q (proxy of firms' market performance) and all the independent variables.The adjusted R2 connotes that the five independent variables explain 55.3% of the variations in the dependent variable. The model is significant at 0.0001. This is a strong indicator that the variables used in the model have sufficiently explained the firms' market performance.The regression results found a relationship that is largely consistent with the correlation results shown in table 3. The results affirm that tax planning plays an insignificant role in the determination of firms' market performance. Again this supports the agency theory's argument that it not all actions of management that help achieve the wealth maximisation objective of management. From the results sales growth and the financial leverage are the two most influential variables. Firms should maintain low financial leverage ratio and pursue sales growth strategies in order to boost their market performance.5. ConclusionsThe study sought to ascertain the level of tax planning offirms and to explore the relationship between tax planning and firms' market performance. The study used 22 non-financial companies over a twelve year period from 2000. The longitudinal correlative designed was used. Thefollowing conclusions are reached.Firstly firms' tax savings decrease as tax authorities reduce the statutory corporate income tax rates. This indicates that leakages in tax revenue as a result of intensive tax planning of firms reduce when tax authorities maintain low corporate income tax rates.Secondly, tax planning has a neutral influence on firms' performance. This finding challenges the general perception that every cedi of tax savings from tax planning reflect in the pocket of investors. Agency problem is much present in the issue of tax planning. The efforts of management to reduce tax burden of firms benefit other stakeholders rather than shareholders. There may be other factors that could ensure that substantial benefits of tax planning accrue to shareholders. Some researchers arguably, root for good corporate governance. This falls outside the scope of this study.Finally, sales growth, firm size, age of firms, financial leverage and tax planning simultaneously play a major role in determining firms' market performance. These variables explain 55.3% of the variations in firms' market performance. Sales growth and financial leverage are the two most influential variables that determine firm market performance.References二、文献综述企业纳税筹划文献综述摘要：20 世纪以来并购已经成为企业快速扩张和整合的重要手段之一。
浅析新时期个人所得税纳税筹划外文资料及翻译(可编辑)
浅析新时期个人所得税纳税筹划外文资料及翻译Superficial analysis of the design of new ear personal income taxBy Jody BlazekAbstractWith China's economic development, personal income increased dramatically, followed by personal income tax burden will increase significantly. Personal income tax planning it caused widespread concern. So the premise of how the tax law, through planning, reduce the tax burden, the article introduced in detail the significance of personal income tax planning and the necessity, personal income tax planning major tax-related items.Keywords: Individual income tax; tax planning; significance; necessity; major tax-related itemsWith the economy growing, gradually raise the living standards of our people, the sources and forms of personal income are becoming increasingly diverse, more and more people become personal income taxpayers. Accordingly, revenue from personal income tax in the proportion also showed a rising trend year by year, to maintain the vitalinterests of the perspective of reducing the tax burden, personal income tax planning more and more taxpayers are highly valued. So how to make the taxpayers under the premise of not against the law, reduce the tax burden as much as possible, to gain imum benefit has become an important research content, the personal income tax planning has become increasingly important.The significance of personal income tax planning and the necessity Many taxpayers from the past secretly or unconsciously adopt various methods to reduce their tax burden, development of active tax planning through to reduce the tax burden. However, in some tax planning ideas and knowledge are often opportunistic together. At the same time some people puzzled: "Tax Planning in the premise is not illegal, but the plan itself is not a violation of the spirit of national legislation and tax policy-oriented it? Desirable tax planning it?" In this context, the correct income tax guide taxpayers on tax planning and tax of the economic development of the more important practical significance, great deal of research necessary.1. Personal income tax planning is conducive to long-term development units.2. Helps to reduce the unit's tax expenditures.3. Helps to reduce the individual's own tax evasion, tax evasion and other illegal acts occur, and enhance tax awareness and realizationof tax honesty.Third, personal income tax planning for tax-related itemsPlanning ideas. First of all, develop a reasonable tax avoidance scheme. Is through the study of the current tax law, income of individuals expected in the near future to make the revenue arrangements, through the time and amount of income, payment, and reaches purpose of reducing the amount of nominal income, thus reducing tax level to reduce the tax burden or exempt taxes. Second, take reasonable tax avoidance strategy. Personal income tax planning can be reasonable to consider the following aspects: improving the level of employee benefits and reduce the nominal income; equilibrium level of wage income each month; can deduct the cost of seizing all opportunities and make full use; use of tax incentives.2. The main tax-related project planning application.1 wage and salary income planning. Progressive tax rates from the nine tables can be seen over, because of the wage and salary income is taken over nine progressive tax rate, so the higher the income, the higher the tax rate applicable to the tax burden heavier. In the periphery of each level, the income may be only a difference of a dollar, but the personal income tax borne by the tax burden will be very different. However, by taking some of the legitimate means of planning, can avoid such an unfair place. There are many specific methods, are:Equilibrium income method. Personal income tax with progressiverates usually, if the taxpayer's taxable income the more, the highest marginal tax rate applicable to the higher, so the average taxpayer's income tax rate and effective tax rate may increase. Therefore, the total income of the taxpayer a period of time given the circumstances, its contribution to the income of each tax period should be balanced, not ups and downs, in order to avoid increasing the tax burden of taxpayers. For example: a staff of 1,500 yuan monthly salary, the company usually taken to the payment of wages, end of year performance-based management approach to implement the pay award. Assuming that the end of the year employees 12 month and get a bonus of 6,000 yuan, then the employee's personal income tax to be paid throughout the year as [1500 +6000 - 2000] × 20% - 375 725 dollars. If the company will be 500 yuan per month by year-end awards along with the payment of wages, the wages of employees for 2000 yuan a month, the annual income for tax purposes.Use of employee benefits planning. Tax payable Taxable income × Applicable tax rate - quick deduction. In the file under the conditions of constant tax rates, reducing their income by way of making their use a lower tax rate, while the tax base is also smaller. Approach is feasible and units agreed to change their payment method of wages and salaries, which some of the units to provide the necessary benefits, such enterprises to provide shelter, it is reasonable tax personal income tax effective way. Enterprises can also provide holiday travel allowance,provide staff welfare facilities, free lunches, etc., to offset their wage and salary income.Cost difference between using the standard deduction. Tax law, deduct the cost of wage and salary income amounted to 2,000 yuan, labor income from more than 4,000 yuan a single 20% of the costs incurred. In some cases, the wage and salary income and income from remuneration for separately, and in some cases the wages and salaries combined with the services will save the tax return, and thus its tax planning to have some possibilities.Cases, Lee February 2006 A company from wages and salaries of 1,000 yuan, the unit wage is too low, the same month in the B Lee to find a part-time company achieved income of 5,000 yuan. If Li and B company does not have fixed employment relationship, in accordance with tax law, wage and salary income and income from remuneration for personal income tax should be calculated separately. A company has made from the wages, salaries did not exceed the deduction limit, do not pay taxes. Obtained from the B company taxable amount of remuneration: 5000 × 1 - 20% × 20% 800 yuan, the Wang in February were 800 individual income tax to be paid; if Mr. Lee and the existence of a fixed B Company the employment relationship, the two should be combined by income wage and salary income to pay personal income tax: 5000 +1000- 2000 × 15% - 125 475 million.Clearly, in this case, the use of wage and salary income tax payablecalculated is wise, therefore, Lee B should be signed with a fixed employment contract, will the income from B Company to the way wages and salaries paid to Lee.2 income from remuneration planning. On income from remuneration of a 20% rate applies, but for the case of a one-time implementation of high income plus collection, in effect amounts to three levels of progressive rates. Income from remuneration has its own characteristics, the following for its characteristics, the analysis of tax planning. Number of planning law. With different wage and salary income, income from remuneration for taxation is based on the number of the standard, rather than months, so the number of times to determine the income tax paid, which is critical to planning for the labor income tax return as a factor when the first considerationRemuneration is based on the standard number of times, deducted a fee each time, so that within one month, the number of labor remuneration paid more the more deductible expenses, the tax should be paid less. So when the taxpayers in the provision of services, reasonable arrangements for tax time, the number of monthly remuneration received, you can deduct legal fees many times, reducing the amount of taxable income each month to avoid the higher tax rates apply, so that their net increased.For example: a public listed company of an expert advisory services, according to the contract, each of the listed company of the expertadvisory fees paid 60,000 yuan. If a tax declaration by a person if their taxable income as follows:One-time reporting taxable income 6-6 × 20% 4.8 million Tax payable 4.8 × 20% × 1 +50% 1.44 millionIf it is 3 times per month, every 2 million tax returns, the amount of tax payable as follows:Payable monthly reporting 2 - 2 * 20% 1.6 millionTax payable 1.6 × 20% 0.32 millionMonthly tax payable 0.32 * 3 0.94 millionWhen comparing the two tax saving 1.44-0.94 0.5 millionCosts offset method. That by reducing the nominal income from remuneration in the form of planning, will cost the taxpayers should be replaced by the owners, to achieve the reduction in nominal labor compensation purposes. Wage and salary income conversion method. Through the wage and salary income into income from remuneration, pay personal income tax by labor income, is more conducive to reducing tax expenditures.Example: Mr. Song is a senior engineer, May 2008 to obtain a company income of 63,700 yuan of wages. Song and the company if the existence of a stable employment relationship, according wage and salary income tax, the tax payable 63700-2000 × 35% -6375 15220 yuan. If the Song and the company a stable employment relationship does not exist, this income istaxed according to perjury.Amount of tax payable 63700 × 1-20% × 40% -7000 13384 yuan. If he can save taxes 1,836 yuan.Summary:As China's economic development, the personal income tax impact on our lives will become increasingly large, and its position will become increasingly important. Making tax planning, each taxpayer must be the extent permitted by laws and regulations reasonably expected taxable income, which is the basic premise. On the basis of protection of interests of the taxpayers through the tax planning to imize personal income tax for the improvement and popularity, with significant practical significance.浅析新时期个人所得税纳税筹划By Jody Blazek摘要随着中国经济的发展,个人收入也急剧增加,随之而来的个人所得税负担也就明显加重。
企业增值税纳税筹划外文文献翻译最新
企业增值税纳税筹划外文文献翻译最新This article discusses the importance of value-added tax (VAT) XXX is a tax on the value added to a product or service at each stage of n and n。
ns pliance.The first step in XXX includes identifying the VAT rates。
ns。
XXX。
It is also XXX.Once the VAT rules are understood。
ns XXX and report VAT。
as well as training XXX.XXX。
This can include taking advantage of VAT ns and ced rates。
as well as optimizing the timing of VAT payments and refunds.Overall。
XXX their financial performance。
It requires a thorough understanding of the VAT rules and ns。
as well as a XXX.译文本文讨论了对于公司而言，增值税规划的重要性。
增值税是对于每个生产和分销阶段所增加的产品或服务价值的税收。
公司可以通过增值税规划来最小化其税务责任，并避免违规行为的罚款。
增值税规划的第一步是了解公司运营所在国家的增值税规则和法规。
这包括确定增值税率、免税和门槛。
同样重要的是确定增值税注册要求和截止日期。
一旦了解了增值税规则，公司可以制定增值税合规策略。
这包括实施系统和程序来准确计算和报告增值税，以及培训员工以确保合规性。
增值税规划还涉及识别增值税节省的机会。
这可以包括利用增值税免税和减税，以及优化增值税支付和退款的时机。
企业纳税筹划外文文献翻译
文献出处：MUCAI G P, KINYA G S, NOOR A I, et al. Tax Planning and Financial Performance of Small Scale Enterprises in Kenya[J].2014：3：1236-1243.原文Tax Planning and Financial Performance of Small Scale Enterprises in KenyaMUCAI G P, KINYA G S, NOOR A IAbstractIn order to ensure the efficiency and effectiveness of activities, reliability and compliance with applicable laws, small scale enterprises need to have adequate tax controls. The study sought to find out the extent to which expenditure on capital assets in tax planning, to determine how tax planning by Capital Structure influence performance of small enterprises, find out how tax planning through Advertisement expenditure influence performance of small enterprises and to assess how tax planning through Legal Forms of enterprise influence performance of small enterprises in Embu CBD. The study had a total population of one hundred and forty nine respondents and a sample of 30 percent was drawn from each stratum. The data was then presented in form of Percentages and Tables. The study found the influence of tax planning by capital structure, tax planning in investment, capital asset planning through advertisement expenditure and found that the Legal Forms of small enterprises in Embu CBD has no significant relationship. The study recommends that small scale enterprises should be ready to seek advice on tax planning. Further to this, the study recommends that there is need to have NGOs to sensitize the respondents as to the need to do formal tax planning as it could increase their Business profitability. Key Words: Tax Avoidance, Tax Evasion, Tax Planning, Capital Structure.IntroductionThe concept of taxation has been a concern of global significance as it affects every economy irrespective of national differences (Oboh et al., 2012). Within thecontext of Africa, tax, a concept as old as mankind can be described as an amount, effort, contribution or service rendered either in kind (goat, cow, farm produce, clearing of grass etc.) or monetary value contributed into a common purse for the running of the society. According to Omotoso (2001), in his definition of the modern taxes, defined tax as a compulsory charge imposed by a public authority on the income of individuals and companies as stipulated by the government decrees, acts or case laws irrespective of the exact amount of services rendered to the payer in return. Thus, taxes constitute the principal source of government revenue and the beauty of any government is for its citizen to voluntarily execute their tax obligations without much coercion and harassment (Adedeji and Oboh, 2012).Tax evasion and fiscal corruption have been a general and persistent problem throughout history with serious economic consequences, not only in transition economies, but also in countries with developed tax systems (Raza, 2011). In general, tax evasion and corruption can have ambiguous effects on Economic growth: tax evasion increases the amount of resources accumulated by entrepreneurs, but it also reduces the amount of public services supplied by the government, thus leading to negative Consequences for economic growth (Roy and Raffaella, 2011). Previous studies highlight reports of declining effective tax rates and a rising proportion of firms that report little or no tax liability. To date, the maintained assumption in much of the literature is that aggressive tax behavior, rather than economic trends, is the driving factor behind this decline (Desai and Dharmapala 2009).The Kenya Revenue Authority (K.R.A) is the tax collection agency of Kenya. It was formed July 1, 1995 to enhance tax collection on behalf of the Government of Kenya. It collects a number of taxes and duties, including: value added tax, income tax and customs. Since KRA's inception, revenue collection has increased dramatically, enabling the government to provide much needed services to its citizenry like free primary education and Health Services to all. Over 90% of annual national budget funding comes from local taxes collected by the KRA (GOK, 2010).It is however important to establish whether the observed increased revenue collection effectiveness has resulted from aggressive tax management by Kenya Revenue Authority (KRA) or whether it is, in part, due to increased use of the new economy business model. This is important because the sources of tax avoidance have distinct policy implications. The policy response to tax avoidance arising from aggressive tax schemes and investments in tax planning is likely to be very different from the response to tax avoidance stemming from a shift in many firms' organizational, operating, and financing attributes, which enable them to exploit their operating flexibility to naturally align with tax incentives that generate tax savings (Drucker 2006).The decreasing trend in effective tax rates may not be solely due to aggressive tax management but Rather, firms' modifications to their business models resulting from changing economic trends potentially enabling them to reduce tax burdens without additional investments in tax planning (Blouin, and Larcker 2011). Performance of Small EnterprisesDifferent approaches are used for performance evaluation in which goal approach, time frame approach, balanced scorecard , system approach, and ineffectiveness approach are included (Jean-Francois, 2004). In stakeholder approach, centre of attention is the ability of a business to meet the needs and expectations of its stakeholders (Daft, 1995).Competing values approach expands the range of other approaches.By using competing values approach, four other models are developed in which rational goal; internal process, open system and human relations are included (Quinn and Rohrbaugh, 1983). Performance of an organization can be evaluated by focusing on problems and retarding factors that inhibit the performance of organizations (Camaron, 1984). Out of the above mentioned approaches, goal approach is the superlative approach to evaluate the performance due to its straightforwardness (Pfeffer and Salancik 1978). Most trendy approach of performance evaluation ofSME's is balanced scorecard approach. Balanced scorecard has four dimensions in which financial growth, quality, customers and learning growth is built-in (Kaplan and Norton, 1992).Balance scorecard actually focuses on maintaining symmetry between monetary and non monetary measures (Neely et al. 1996).Book-tax differences, on average, are systematically related to earnings growth, future stock returns, and earnings persistence (Hanlon, 2005) and among other implications, book-tax differences are useful measures in evaluating firm performance. Consistent with these studies, Shevlin (2002) and Hanlon, Laplante, and Shevlin (2005) find that while book income explains a firm's annual stock returns better than estimated taxable income, estimated taxable income, on average, has incremental explanatory power for book income. However , there is little evidence regarding taxable income as an alternative performance measure and, in particular, cross-sectional differences in firms that mitigates or enhances the ability of taxable income to inform investors regarding firm performance (Lev and Nissim, 2004).Some SME's compare their performance with that of other SME's. They evaluate their performance by means of comparative analysis. Performance can also be evaluated by means of ineffectiveness approach. In ineffectiveness approach, focus is on the factors that hampers the feat of organizations. Therefore this study seeks to investigate the extent to which Tax Planning influences Financial Performance of Small Enterprises in Embu town CBDTax PlanningThe implementation situation of SME income tax planning is distorted tax planning, that is to say, on the one hand, more and more SME pay tax in accordance with the law, and on the other hand, because of the role of the interest mechanism and other various reasons, more and more SME tax-related cases appear (Karing and Wanjala, 2005). According to the survey, the vast majorities SME have not yet started or are considering carrying out tax planning, which can not fight for the legitimate tax interests and ruin financial interests leading to a large number of emerging additionaltax burden (Fjeldstad and Rakne, 2003). In addition, SME tax planning is treated unreasonable. Due to the limitations of the concept, SME tax planning activities often encounter misunderstanding, punishment and censor from some basic taxation law enforcement agencies (Karing and Wanjala, 2005).Tax law is said to be barely connected with the universe and with universal law as we understand it. However, tax law is founded not only on principles but also on practicality. There is no element of perpetuity about tax law, only the constant clash of the immediate and semi permanent (Kibua and Nziok, 2004). A State cannot run a democracy well without taxation and a taxation system cannot be run well without democracy. Oliver Wendell Holmes has said on one occasion, "Taxes are what we pay for civilized society" (Neely et al. 1996).Statement of the ProblemTax reform today has been moving towards considering new legislation, such as whole new taxes or reliefs, rather than patching of existing taxes by either increasing or decreasing the amount of taxation. This breaks down into the fact that there are ongoing considerations of widening the tax base. Kenya is no exception to this and there are ongoing considerations into taxing the informal or "jua kali' sector including the taxation of the "mitumba', the second hand clothing industry as well as the taxation of all informal tax payers of small amounts.A question that appears to generate surprisingly little debate in Kenya is the scope for legally mitigating taxes payable by individuals and corporate entities. Tax planning is bound to gain increasing significance with the ever greater aggressiveness and sophistication of the Kenya Revenue Authority and other tax collecting bodies. The trend of increased aggressiveness and sophistication in tools and methods is occurring against a backdrop of a public policy of domestic sources being the primary sources of revenues for budgetary purposes. This results in governmental pressure on tax collecting agencies to improve their revenue collection performance. The result of this trend is the more stringent enforcement of taxation laws. The past and presentpractice by many of outright evasion is, and likely will continue to be, fraught with risk.Examining the relation between the new economy business model, tax avoidance and investments in tax planning is important as previous Studies in the tax avoidance literature generally examine how specific firm attributes are related to tax avoidance independently, rather than investigating how firms' overall business models facilitate or hinder effective tax planning (Frank, Lynch, and Rego 2009). Hanlon and Heitzman (2010) argue that despite the much literature, these do not explain the variation in tax avoidance very well. Therefore due to this and such seemingly inexorable trends, the question of tax mitigation by legitimate avoidance naturally occurs. This study intends to find out the influence of small Enterprises tax planning within the current legal environment so as so minimize their tax burden. ConclusionDue to the corruption levels, low business growth, and management of public finances in the economy, where there is a great extent of corruption, has a related to a high level of tax evasion and the study concluded that there was no relationship between tax planning in investment in capital asset and performance of small enterprises in Embu CBD. The study concludes no significant relationship. The study concludes also that no significant relationship exists between tax planning through advertisement expenditure and performance of small enterprises in Embu CBD and also concluded there was no significant relationship the Legal Forms of enterprise tax planning and performance of small enterprises in Embu CBD. RecommendationsThe tax authorities should address the lack of formal tax planning as this may be a way of evading taxation in the name of tax avoidance. The small scale enterprises should also be ready to open up to advice on tax planning to make savings lather than playing a hide and seek game with tax authorities. Further to this, the study recommends that there is need to have NGOs to sensitize the respondents as to theneed to do formal tax planning as it could increase their Business profitability Implications on Policy Theory and PracticeThis study though confined to investigate the influence of tax planning on financial performance of small scale enterprises has established that little tax planning take place among the small enterprises and therefore tax Authorities and the chamber of commerce should write a position paper to address the awareness and use of tax planning by small scale enterprises. This would improve the growth rate of the small enterprises and there after the growth of the economy.译文肯尼亚小规模企业的纳税筹划与财务业绩保罗，萨洛姆，努尔摘要为了确保活动的效率和有效性，适用性法律的可靠性与遵从性，小规模企业需要有足够的税收管制。
纳税筹划文献综述及外文文献资料
本文档包括改专题的：外文文献、文献综述一、外文文献文献信息标题：Effect of Tax Planning on Firms Market Performance: Evidence from Listed Firms in Ghana 作者：Kawor, Seyram; Kportorgbi, Holy Kwabla期刊：International Journal of Economics and Finance第6卷，第3期，页码：162-168，2014年Effect of Tax Planning on Firms Market Performance: Evidence from Listed Firms in GhanaKawor, Seyram; Kportorgbi, Holy KwablaAbstractThe study sought to ascertain the level of tax planning of firms and to explore the relationship between tax planning and firms' market performance. The study used 22 non-financial companies listed on the Ghana Stock Exchange over a twelve year period from 2000. The longitudinal correlative designed was used. The results indicate that that firms' tendency to engage in intensive tax planning activities reduces when tax authorities maintain low corporate income tax rates. Secondly, tax planning has a neutral influence on firms' performance. This finding challenges the general perception that every cedi of tax savings from tax planning reflect in the pocket of investors. It is concluded that investors must institute systems to ensure tax planning benefits reflect significantly in their pockets.Keywords: Ghana stock exchange, tax planning, market performance, longitudinal correlative design, investors1. IntroductionOver the years and throughout the world, the history of taxation brings out one fact; that taxes are coercive in nature and therefore economic units which are assigned the tax liability never wholly intend to bear the actual tax burden (Commonwealth Association of Tax Administrators (CATA), 2007). Economic units, more specifically, corporate bodies are always adopting ways to minimise, postpone, or avoid entirely, the payment of tax. The attempts by the economic units to reduce, postpone or avoid tax payment can be legal or illegal. The legal means is called tax planning while the illegal means is called tax evasion. The dire consequence of tax evasion makes it an unattractive option for listed companies (Murphy, 2004).The practice of tax planning dates back to 1947 when learned judge Hand, in the case Commissioner v Newman, held that there is nothing sinister in arranging ones affairs so as to keep taxes as low as possible. Hoffman's (1961) tax planning theory supports this argument. According to Hoffman, it is a necessity for firms to understand the prevailing tax laws and apply the laws in a manner that ensures the firms minimise their tax exposure. Hoffman posits that it makes no economic sense to pay more tax than what the law demands. Scholes and Wolfson's (1992) tax planning framework also underscores the need for corporate bodies to engage in tax planning. According to Scholes and Wolfson, a successful company is the one that is properly attuned to its tax environment.International governmental organizations, such as CA TA (2009), suggest that corporate bodies in Ghana, especially the large entities, engage in complex tax planning activities. Research by civil society groups such as Christian Aid (2008), Action Aid (2011), and Dan Watch (2011), confirm this assertions made by the Domestic Revenue Division. The missing element in the findings is thequantitative expression of the tax planning activities of the firms.The traditional thinking is that firms that derive maximum benefit from tax planning perform better than those that do not plan their taxes (Murphy, 2007). From the empirical perspective, tax planning is positively associated with firms' performance. For instance, Desai and Hines (2002); Chen, Chen, Chen and Shelvin (2010) reported positive association between tax planning savings and firm performance. The argument is that tax represents cost of doing business, and any action that has the potential of minimising tax cost reflects in higher firm performance. This argument presupposes that tax planning cost and risk does not exceed the savings from the planning.Few studies in the UK dispel the traditional relationship between tax planning and firm performance. While admitting that tax planning has a positive association with accounting performance, Desai and Dharmaphala (2007) reported that tax planning has a neutral association with market performance. Indeed Abdul-Wahab (2010) found a negative association between tax planning and firm performance. Kportorgbi (2013) suggested that corporate governance strength plays a mediating factor in the tax planning-firm performance relationship.A study of the effect of tax planning savings on firms' market performance is crucial for all stakeholders in the emerging security markets such as the Ghana stock Exchange. In fact each possible relationship has a unique implication for the players. For instance, a positive association implies that tax planning produces a win-win situation for both management and shareholders (investors). A negative association connotes that tax planning benefits may not eventually trickle to the pocket of the shareholder. Indeed, a negative association may be an indicative of the existence of agency problem, where management is inclined to pursue tax planning to enhance their own lot rather than advancing the interest of the investor. Where a neutral association is established, it will invoke a follow up study on the possible factors that could influence the relationship either positively or negatively. Secondly, the study is necessary to inform tax planning agents and investors on the dynamics of tax planning1.1 Objective of the StudyThe primary objective of this study is to explore the relationship between tax planning savings of firms listed on the Ghana Stock Exchange and firm market performance. The study also seeks to examine the simultaneous influence of other firm specific variables on the tax planning-market performance relationship.1.2 Tax Planning Intensity of Firms in GhanaCommentators on tax behaviour of firms in Ghana paint a picture that suggests that large firms engage in tax planning activities. For instance CATA (2009) posits that Ghana Revenue Authority lost seventy-four million pounds between 2005 and 2007 to the European Union (EU) in tax revenue as a result of tax avoidance by several multinational companies. Murphy (2004) also reported that firms have complex gamut of arsenals to reduce their tax burden. The reports indicate that the tax avoiding mechanism of firms are largely allowed by the tax laws. There are also indications that the firms take advantage of the loopholes in the tax laws to derive unintended tax benefits. The avenues for tax planning usually revolve around locational reliefs, industry-specific concessions and capital allowance provitions. Others are time variables and entity variables.Most of the reports are not precise in their estimation of the benefits that firms achieve through tax planning. The lack of precision in measuring tax planning intensity is largely attributed to the insufficient reporting of issues of taxation by firms. Aside the mandatory disclosures to tax authorities, firms are reluctant in disclosing much on tax behaviours. This is due to the perceivedthin line that exist between tax planning and tax evasion. Listed companies, however, provide provide adequate information necessary to estimate the tax savings of the firms. This is made possible by virtue of the financial reporting guidelines provided by the security exchange commision.2. Review of Related LiteratureThis section is subdivided into theoretical review and empirical review. The theoritical review encapsultes the Hoffman's (1961) tax planning theory. Three main empirical studies are reviewed. They are Desai and Hines (2002), Desai and Dharmaphala (2009) and Abdul-Wahab (2010).2.1 Hoffman's Tax Planning TheoryAccording to Hoffman (1961) tax planning seeks to divert cash, which would ordinarily flow to tax authorities, to the corporate entities. Tax planning activities are desirable to the extent that they reduce taxable income to the barest minimum, without sacrificing accounting income. The theory is premised on the fact that firms tax liability is based on taxable income rather than accounting income. The idea is thus to intensify activities that reduce taxable income but has no indirect relationship on accounting profit. The theory thus recognised a positive association between firm tax planning activity and firm performance.Hoffman (1961) also recognised the role of tax cost in the tax planning activities. The theory thus provided that the positive association between tax planning and corporate performance is on a basic assumption that tax benefits from the tax planning exceed tax cost. The scope of the Hoffman's tax planning theory does not address the dynamics of tax planning and market performance. As capital markets develop and the separation of ownership and control of corporate bodies become well-spread, the need for a comprehensive tax planning theory is imperative. This need is rather addressed through the empirical perspective than through theoretical perspective (Inger, 2012).2.2 Empirical Review and Development of HypothesisDesai and Hines (2002) provide evidence on firm performance and tax planning behaviour of firms. Again, the study investigates the relationship between tightening of tax systems and market value of firms. The study was based on 850 listed US firms. The study sample was purposively selected to reflect the characteristics desired by the researchers. The study was cross sectional and the data relates to year 2000. Correlative-description design was adopted. Simple regression and t-tests were used to establish the relationships. Desai and Hines established that intensive tax planning is associated with higher firm performance. On the other hand, the study reported that tightening of the tax system is positively associated with higher market performance of firms. The findings of Desai and Hines (2002) are similar to that reported by Chen, Chen and Chen (2010). Desai and Dharmapala (2007) provided a comprehensive study that incorporates tax planning, corporate governance and firm performance. The study used 4,492 observations on 862 firms over the period 1993 to 2001. This panel data was drawn from the Compustat and Execucomp databases, merged with data on institutional ownership of firms from the CDA/Spectrum database. Firms' performance is measured using Tobin's q and governance quality is proxied by the level of institutional ownership. Tax planning is measured by inferring the difference between the income reported to capital markets and tax authorities (the book-tax-gap). Two analysis models were adopted-the OLS model and the IV estimation model. The OLS results shows that the average effect of tax planning on corporate performance is not significantly different from zero. In other words, there is no relationship between tax planning and firm performance. The study howeverreports a positive association between tax planning savings and performance for well-governed firms. Desai and Dharmapala (2007) thus concluded that corporate governance mediates the tax planning-firm performance relationship. The IV estimate shows a higher effect of corporate governance on firm performance.Abdul-Wahab (2010) provides a result that differs from the findings of Desai and Hines (2002), Desai and Dhamarpala (2009), and Chen, Chen, Chen and Shelvin. Abdul-Wahab's (2010) study sought to establish a relationship between tax planning savings of firms and their value. The study simultaneously investigates the moderating influence of corporate governance. Abdul-Wahab's study employed 240 firms listed on the London stock exchange from 2005 to 2007. Tax planning was proxied by the difference between the effective tax rate of the entities and the applicable statutory tax rates. Self-constructed governance index was constructed using corporate governance mechanisms. Firms' value was represented by the Tobin's Q. The data was analysed using panel regression analysis model. As a check, the OLS model was also used.The results indicate a negative relationship between firm value and tax planning activities. Abdul-Wahab (2010) explains the relationship with reference to tax planning cost and risk. The study suggested that tax planning cost and risks associated with tax planning have the potential of derailing the benefits that should have accrued to shareholders. The researcher maintains that as tax planning activities increase, the tax costs and risks outweighs the benefits.Due to the diversity of the relationships found between tax planning and firms' market performance, it is right to develop a null hypothesis as:H1: There is an association between tax planning and firms' market performance.It is unreasonable to suggest that tax planning is the only determinants of firm performance. Baring the existence of multicollinearity between (among) the explanatory variables, sales growth, financial leverage, firm size and age of the firms will be introduced into the regression models. Several studies, including Desai and Hines (2002), Desai and Dharmaphala (2007), Abdul-Wahab (2010) reported positive association between firm performance and sales growth, firm size and financial leverage. It is thus clear to develop the null hypothesis that:H2: Firm performance and sales growth and firm size are positively associated.Firms' age, according to Desai and Dharmapala (2007) and Abdul-Wahab (2010) has a negative association with market performance of firms. This gives rise to the third null hypothesis that:H3: Firms age and financial leverage are negatively associated with firms' market performance. 3. MethodologyLongitudinal correlative design is adopted for the study. Longitudinal design is essential if the same research entities sampled in a cross section are then re-sampled at different times (Creswell, 2009; De Vaus, 2001). According to the authors, the design helps overcome limitations associated with the "snap shot" approach of cross sectional designs.The study population comprises all non-financial firms listed on the Ghana stock exchange. As of June 2013, twenty-three (23) out of thirty-five (35) firms listed on the Ghana Stock Exchange were non-financial companies. Financial companies are excluded from the population. Previous researchers posit that the financial sector is a highly regulated sector and as such regulations blur the relationship that exist among the variables to be studied (O'Hamon & Taylor, 2007; Desai & Dharmapala, 2009; Abdul-Wahab, 2010).The study uses a panel data for twelve-year period, from 2000 to 2011. Data for the study is collected from the database of the Ghana Stock Exchange. Panel regression model is adopted fordata analysis and the Ordinary least square (OLS) been the method of regression.The regression model is summarized as: (1)α = (alpha) shows the constant affecting net profit margin on corporate tax.Tobin's q (market performance) = (market capitalization of entity) ÷ (book value of shareholders fund).Tax savings = Statutory tax rate -Effective tax rate.Statutory tax rate = flat rate as mandated by the Ghana Revenue Authority.Effective tax rate = Corporate income tax expense/profit before tax.Sgrowth (sales growth) = (Previous Sales revenue -Current sales revenue) ÷Previous sales revenue.Fsize (firm size) = Natural log of firm's total assets.fLev (Financial leverage ) = Long term debt/shareholders fund.Age (Age of firms) = log(the difference between the year of establishment and years of observation).4. Results and DiscussionFigure 1 and Table 1 presents the descriptive statistics for two key variables, namely tax planning of firms and market performance over the twelve year period.Like the statutory rate, tax savings of firms show a decreasing trend. As tax authorities take steps to reduce the tax burden on firms, the leakages in tax revenue due to firms tax planning activities reduce. From figure 1, the statutory tax rate reduced from about 32% to 25%. Tax savings of firms reduced also from 15% to 8% by 2011. That is to say each percentage point decrease in the statutory rate leads to a corresponding decrease in firms' tax planning savings.The policy implication of this finding is two-fold. Firstly, the notion of increasing tax rate in order to rake in more tax revenue may not hold. As tax rates increased, the motivation of firms to deny the state of revenue through intensified tax planning machinery is enhanced. Secondly, as the tax rate is decreased, the net benefit of planning tax is derailed. The way forward for tax revenue optimisation is to maintain lower tax rates and drag more firms into the tax net.Table 1 provides the market performance of the firms over the twelve year period.The farther the Tobin's Q is from unity, the better the company performance. From Table 1, all the company groups recorded an average score higher than 1.00. The overall average score is 1.78 (the median represents the average as skewness is negative). The high average market performance by the firms is driven by only the mining sector and the manufacturing companies. All the remaining classes of companies recorded lower than the average score.This finding confirms the observation of business persons in Ghana that business climate in Ghana gives unmatched advantage to the mining sector. The service sector records the lowest market performance. This raises a major concern as the sector is the major contributor to gross domestic product (GDP) in Ghana. Another sector to watch out for is the oil and gas. This sector has the most recent history. It was expected that the high hopes of investors in the sector after the discovery of oil in commercial quantities in Ghana would have positive influence on the performance. It is expected that the sector will be one of the major drivers of firms' market performance in the future.Table 2 provides correlation results on the variables. This result is essential for at least two reasons. Firstly, it shows basic association between the dependent variable (market performance) and theindependent variable. Secondly, it shows if the "so-called" independent variables are indeed independent. In other words, it tests the multicollinearity status of the independent variables. From Table 2, the correlation co-efficient between tax savings and Tobin's Q is 0.112. This is however significant at 0.097. This significant level is compared with the default alpha of 0.05. As rule of thumb, we reject the null hypothesis if the actual significant level is higher than the expected alpha and do not reject if the actual significant is less than the expected alpha. In this instance p-value of 0.097 is greater than the expected alpha of 0.05. The null hypothesis that:H1: There is an association between tax planning and firms' market performance is rejected.The correlation results do not suggest causation but gives an indication of association between the variables. The "no relationship" finding between tax planning and firms' market performance supports the reports of Desai and Dharmapala (2007) but differ from the findings of Desai and Hines (2002) and Abdul-Wahab (2010). The findings suggest that although savings from tax planning reflect in higher profit after tax, it does not necessarily reflect in the pocket of shareholders. This finding ignites studies aimed at uncovering factors that mediate the tax planning-firm performance relationship. Indeed, it might be the reasons behind the works of Desai and Dharmapala (2007), Desai and Dharmapala (2009) and Abdul Wahab (2010).Another finding in table 3 is the relationship between market performance (proxied by tobin's Q) and the firm specific variables. Sales growth and firm size shows positive and significant association with firms' market performance. On the other hand financial leverage and age of the firms shows a negative association with firm performance. The findingsWe do not reject the null hypotheses (H2 and H3) stated asH2: Firm performance and sales growth and firm size are positively associatedH3: Firms age and financial leverage are negatively associated with firms' market performance. Further Table 3 gives an indication that multicollinearity among the independent variables does not exist. The rule of thumb is that if the correlation coefficients between any two of the variables is above 0.50 (either positive or negative), those two variables are multi-correlated and should not be simultaneously included in the regression model. From Table 3, this condition does not exist. The variables can be regressed against the dependent variables.Table 3 shows the regression of Tobin's Q (proxy of firms' market performance) and all the independent variables.The adjusted R2 connotes that the five independent variables explain 55.3% of the variations in the dependent variable. The model is significant at 0.0001. This is a strong indicator that the variables used in the model have sufficiently explained the firms' market performance.The regression results found a relationship that is largely consistent with the correlation results shown in table 3. The results affirm that tax planning plays an insignificant role in the determination of firms' market performance. Again this supports the agency theory's argument that it not all actions of management that help achieve the wealth maximisation objective of management. From the results sales growth and the financial leverage are the two most influential variables. Firms should maintain low financial leverage ratio and pursue sales growth strategies in order to boost their market performance.5. ConclusionsThe study sought to ascertain the level of tax planning of firms and to explore the relationship between tax planning and firms' market performance. The study used 22 non-financial companies over a twelve year period from 2000. The longitudinal correlative designed was used. Thefollowing conclusions are reached.Firstly firms' tax savings decrease as tax authorities reduce the statutory corporate income tax rates. This indicates that leakages in tax revenue as a result of intensive tax planning of firms reduce when tax authorities maintain low corporate income tax rates.Secondly, tax planning has a neutral influence on firms' performance. This finding challenges the general perception that every cedi of tax savings from tax planning reflect in the pocket of investors. Agency problem is much present in the issue of tax planning. The efforts of management to reduce tax burden of firms benefit other stakeholders rather than shareholders. There may be other factors that could ensure that substantial benefits of tax planning accrue to shareholders. Some researchers arguably, root for good corporate governance. This falls outside the scope of this study.Finally, sales growth, firm size, age of firms, financial leverage and tax planning simultaneously play a major role in determining firms' market performance. These variables explain 55.3% of the variations in firms' market performance. Sales growth and financial leverage are the two most influential variables that determine firm market performance.References二、文献综述企业纳税筹划文献综述摘要：20 世纪以来并购已经成为企业快速扩张和整合的重要手段之一。
税收筹划分析英文外文
Tax planning refers to the extent permitted by laws and regulations, through business, investment, financial activities and arrangements in advance planning to minimize tax costs, to maximize the tax benefits of an economic act. The expectation of any taxpayer to reduce tax burden because they often require a minimum of input, maximum output, in order to achieve the goal of maximizing enterprise value, which is the demand for tax planning motives and economic base. In recent years, people have come to understand that although the importance of tax planning, but often as a result of tax planning provisions in the tax laws of the edge of the operation, and the state’s tax policy, tax laws and regulations and changing risk estimates of tax planning not enough, resulting in a tax were economic, such as a waste of time, more harm than good, and they even find stolen, the abyss of tax fraud. Therefore, the risk of all times.For enterprises, the only fully aware of the existence of tax planning risks and understand their motives have, in accordance with the current tax law, combined with their own conditions, with the preferential policies the state fully in order to make effective tax planning measures, The ultimate goal to reduce corporate tax burden, improving economic efficiency.。
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关于税收筹划的论文税务筹划是纳税人在法律规定许可的范围内，通过对投资、筹资、经营、理财等活动进行事先安排和筹划，尽可能减少不必要的纳税支出。
以谋求最大限度的纳税利益，实现企业税后利润或现金流量最大化。
税收对国家来说是为了实现其职能，凭借政治权利按预定标准无偿地参与国民收入分配的一种手段；而对纳税人来说则是资金的净流出，节约税款支付等于增加纳税人的净收益。
本文从税务筹划的必然性和如何进行税务筹划两个方面谈一下自己对税务筹划的认识。
一、税务筹划的必然性我国是法治国家，纳税人必须根据税法的规定性履行纳税义务。
而纳税必然减少纳税人的净利润，为了在合理、合法、合规的情况下达到节税，实现利润最大化的目标，纳税人必须进行税务筹划。
即，环境是一定的，只有适应环境，才能改变自我。
我们的环境是：来源于市场，适应于市场。
而在市场运行中又必须遵循一定的市场规则，适应、掌握并较好地运用这些市场规则，最终实现纳税额度最低，企业利润最大，市场份额占有率最高，进行税务筹划是我们的必由之路。
1、企业追求股东财富最大化使税务筹划成为必然；企业要生存、发展、获利，盈得社会各界人士的好评，获得投资者最大额度的投资。
追求股东财富最大化是他的根本目标。
实现该目标的途径总体来说有两条：一是增加企业收入，二是降低企业成本费用。
而税款就作为一项费用而存在，在收入不变的情况下，降低税务支出，就等于降低成本费用，从而实现股东财富最大化。
2、税法的规定性、法律的严肃性使税务筹划成为必然；所谓税务筹划，是指在投资、筹资、经营、股利分配等业务发生之前，在法律、法规允许的范围之内，事先对纳税事项进行安排，以达到最低纳税额度。
而一旦投资、筹资、经营、股利分配等事项已发生，那么纳税义务就已经产生，这时再想方设法少交税款，就成为偷税、漏税，必将受到法律处罚。
合理、合法、合规、及时、有效地进行税务筹划就象一把双刃剑，一方面使企业遵纪守法；一方面降低企业成本费用，增加净利。
最终达到增强企业活力，提高的社会效益和经济效益的目的。
3、税务筹划是纳税人行使的一项基本权利，经过税务筹划纳税义务会变得积极、主动、简捷而明了。
权利和义务是一对相互依存、相辅相成的矛盾。
依法纳税是纳税人应履行的一项基本义务，而在合理、合法的范围内进行税务筹划则是纳税人行使的一项权利。
进行税务筹划使纳税人被动的纳税行为（即税务机关征多少，纳多少）变成了一种具有主观能动性的行为，为了使企业利润最大化，为了最大限度的减少纳税额度，纳税人会进行一系列测算、规划、分析、对比，设计几套纳税方案，然后选择其中最优的使用。
这里所指最优包括税额最低；操作最简便；使用最明了等等。
对征税机关来说，利用纳税人的这种积级性，不但抑制了偷税、漏税、逃税；而且方便了征税。
从而鼓励纳税人依法纳税，提高纳税人的纳税意识。
二、如何进行税务筹划税务筹划是减轻企业税收负担，增强企业税后利润的一种战略性筹划活动，具体来说，我们从以下几个方面进行税务筹划。
（一）全局性是税务筹划的显著特征；随着市场经济的发展，企业经济出现了多元化、多渠道、覆盖面宽，涉及范围广的趋势，税务筹划不再仅仅是一种行业、一个部门、一种产品基础上的单纯的筹划活动，而成为触动企业发展全局，减轻企业总体税收负担，增强企业税后利润的一种战略性筹划活动。
随着市场经济的发展，企业合并、分立、重组不断拥现，税务筹划的全局性显得尤为重要，通过筹划缩小税基、适用较低税率，合理归属企业所得的纳税年度，延缓纳税期限，实行税负转嫁，进而降低整个企业的税负水平。
一般可以考虑的操作方法有：1、企业组建过程中的税务筹划。
包括企业组建过程中公司制企业与合伙制企业的选择；设立分公司与子公司的选择。
公司制企业既要交纳企业所得税又要交纳个人所得税，合伙制企业仅交纳个人所得税；如果设立公司享受税收优惠则设立子公司，如果经常亏损有负债经营的好处则设立分公司。
2、企业投资过程中的税务筹划。
投资涉及选择投资地区、投资行业、投资类型。
比如，在中、西部与东部投资会享受不同的税收优惠；选择服务行业和生产行业会适用不同的税种；而选择了生产行业，生产不同的产品又有不同的税收规定。
Papers on the tax planning tax planning is provided for taxpayers to the extent permitted by law, through investment, financing, management, financial management and other activities and planning in advance, as far as possible to pay taxes to reduce unnecessary expenditures. To seek to maximize tax benefits, or after-tax profit of enterprises to maximize cash flow. Of taxation in the country is to achieve its functions, by virtue of political rights according to predetermined criteria to participate in free of charge as a means of distribution of national income; of taxpayers is a net outflow of funds, the payment is tantamount to increasing the tax savings of taxpayers net. In this paper, the necessity of tax planning and tax planning for how to talk about two aspects of their understanding of tax planning.First, the inevitability of tax planningChina is a country ruled by law, the taxpayer must, in accordance with the provisions of tax law to fulfill our obligation to pay tax. The tax will inevitably reduce the taxpayer's net profit, to a reasonable, legal, compliance to achieve the tax saving to achieve the goal of profit maximization, the taxpayer must be tax planning. That is, the environment is a must, and only to adapt to the environment in order to change the self. Our environment is: from the market and adapt to the market. Operation in the market must follow certain rules of the market, adaptation, and have better use of these market rules, and ultimately the amount of the minimum tax, the largest corporate profits, the highest share of the market share, tax planning is the onlyway we are.1, enterprises seek to maximize shareholder wealth so that tax planning has become inevitable;Enterprises to survival, development, profit, profit may well all sectors of the community, access to investors, the largest amount of investment. The pursuit of shareholder wealth maximization is a fundamental goal of his. Way to achieve this goal the whole there are two: First, to increase business income, and the other is to reduce business costs. And as a tax on the cost of the existence of the same in the case of income, reducing tax expenditures, it means lower costs and thus maximize shareholder wealth.2, the provisions of tax law and the solemnity of the law so that tax planning has become inevitable;The so-called tax planning, is defined as investment, financing, management, dividend distribution and other business before the law and regulations within the scope of the permit, prior arrangements for the tax matters in order to achieve the minimum taxable limit. Once the investment, financing, management, matters such as dividend distribution has occurred, then the tax has been generated, then the amount of tax evaded try again becomes tax evasion, will be subject to legal penalties. Reasonable and legal, regulatory compliance, timely, effective tax planning is like a double-edged sword, on the one hand, law-abiding enterprises; on the one hand, reduce costs, increase net profit. The ultimate goal to enhance the vitality of enterprises, improve the social and economic efficiency.3, it is the taxpayers tax planning exercise a fundamental right, after the Inland Revenue tax planning will become positive, active, simple and clear.Rights and obligations are interdependent and mutually reinforcing contradictions. Taxpayers should be in accordance with the law, paying taxes is a basic obligation to fulfill, and at a reasonable and legitimate tax planning framework is a right exercised by the taxpayer. Tax planning to allow taxpayers to tax passive behavior (ie, the number of tax authorities levy, how much satisfaction) has become an initiative of the act, in order to maximize corporate profits, in order to minimize the amount of tax, the taxpayer will be a series of calculations, planning, analysis, comparison, design sets the tax program, and then choose the best one to use. Here, the best, including the minimum tax; the most simple operation; use of the most clear and so on. Of the tax authorities are concerned, the use of such a plot-class taxpayers, and not only curbed tax evasion, tax evasion; and convenient taxation. In accordance with the law so as to encourage taxpayers to pay taxes, raise the awareness of taxpayers to pay taxes.Second, how to carry out tax planningTax planning is to reduce the corporate tax burden, and enhance after-tax profits of a business strategic planning activities, in practical terms, the following aspects of tax planning.(A) of the overall tax planning is a significant feature;With the development of the market economy, enterprise economy has diversified, multi-channel, wide coverage, involving a wide range of trends, tax planning is no longer just an industry, a sector, a product purely on the basis of planning activities, enterprise development as a global touch to reduce the overall tax burden on enterprises, and enhance after-tax profits of a business strategic planning activities. With the development of the market economy, corporate mergers, separation, reorganization is constant over, the overall tax planning is especially important, through the plan to narrow the tax base and lower tax rates applicable and reasonable attribution of the annual corporate income tax, the tax deadline to postpone the implementation of shift the tax burden, thereby reducing the tax burden on the level of the entire enterprise. The general method of operation can be considered are:1, firms in the process of tax planning. Including the formation of the process of business enterprises and corporate enterprises the choice of partner; set up branch offices and subsidiaries choice. Corporate enterprises should not only have to pay corporate income tax to pay personal income tax, partnership enterprises to pay personal income tax only; if setting up a company to enjoy tax incentives set up a subsidiary, if the regular operation of a loss of the benefits of contingent liabilities are set up branch offices.2, business investment and tax planning process. Investment in areas related to their choice of investments, investment industry, the type of investment. For example, in the western and the eastern part of the investment will enjoy different tax breaks; choose the service sector and manufacturing industry will be subject to different tax; and choose the production industry, the production of different products have different tax provisions。