중국 증치세 수출환급제도의 변화와 그 시사점

Abstract

This paper studies the change and its meaning of tax refund system in Chinese VAT. Chinese VAT system experienced various try and error since China government introduced VAT system in 1994. Now, Chinese tax refund system has two types, of which one is first-collection-and-refund-later and the other is exemption-credit -refund. Tax refund rate has been increased or decreased according to Chinese export amount and fiscal condition. Problems which Chinese VAT refund system has is as follows. First, partial refund system impairs the purport of the prevention of double taxation in GATT and destination principle of taxation in border tax adjustment. Second, partial refund system may weaken international competitive power and worsens profitability and financial condition of exporting company. Third, partial refund system conflicts with principle of simplicity and efficiency in taxation because the system is very complex to enforce and collection cost is very high. And also, it is difficult for taxpayer to comply and understand the system. Fourth, various frequent alteration of refund rate lessens predictability and legal stability. In change of Chines VAT refund system, what this paper suggests is as follows. First, professionals and scholars on Chinese VAT system have to argue that Chinese government needs to revise its tax law to harmonize with international legal standard. And investors to China have to claim to refund tax reliably according to Chinese tax policy. Second, it is possible that Chinese VAT system changes production type into consumption type. It is just evidence that three north-east states and six middle states introduced the system of purchase tax credit in capital goods in 2004 and 2007.