| 平台经济背景下税源与税收相统一的规范促进 |
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| 引用本文：蒋悟真，冯楚羚.平台经济背景下税源与税收相统一的规范促进[J].财经理论与实践,2026,(3):151-160 |
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| 中文摘要:平台经济高度开放性和跨域性的生产组织形式引发的经济资源流动模式革新加剧了税收与税源分离的问题。税源背离具有加剧税源成本负担、阻碍生产要素流通、忽视用户价值创造等不足，故学界普遍对其持否定态度。但此种刻板印象忽视了税源背离所蕴含的促进财政权责对应、提升税收分配效率、推动区域融合等合理性成分。与其说税源背离是一个需要解决的“问题”，毋宁说其揭示出现有区际财政秩序仍有改进空间。基于此，对税源背离应采取有限规制，依循“适当性-必要性-均衡性”框架厘定规制边界。考虑到区际财政秩序革新的复杂性，可采取渐进策略：首先，以起点公平为主旨，通过“赋值”保障税收流出地享有底线性税收。其次，以机会公平为目标，通过改变应税联系和多因素认定法，使税收流出地获取与贡献匹配的税收。最后，以结果公平为要旨，通过相对精准量化完善应税联系规则。落实到税制层面，基于我国现行税制结构，应以构建与价值贡献结构对应的增值税多地分享原则、扩充平台多元模式下企业分支机构的认定方式、设立平台履责和用工企业数字化虚拟分支机构代扣代缴规则为改革重点。 |
| 中文关键词:平台经济 税源背离 规制限度 区域税收分配 价值创造结构 |
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| Standardization and Promotion of the Unification of Tax Revenue and Tax Sources under the Background of Platform Economy |
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| Abstract:The innovation of economic resource flow pattern triggered by the highly open and cross-regional production organization forms of the platform economy has exacerbated the problem of the deviation between tax revenue and tax sources. Divergence between tax revence and tax source has shortcomings such as intensifying the cost burden of tax sources, hindering the circulation of production factors, and neglecting the creation of user value. Therefore, the academic community generally holds a negative attitude towards it. However, this stereotype neglects the reasonable components contained in divergence between tax revenue and tax sources, such as promoting the correspondence of fiscal rights and responsibilities, improving the efficiency of tax distribution, and promoting regional integration. Rather than being a “problem” that needs to be addressed, divergence between tax revenue and tax sources reveals that there is still room for improvement in the inter-regional fiscal order. Based on this, limited regulation should be adopted for tax source deviation, and the regulatory boundaries should be determined in accordance with the framework of “appropriateness- necessity-balance”. Given the complexity of the reform of the inter-regional fiscal order, a gradual strategy can be adopted: Firstly, with the aim of fairness at the starting point, ensure that the tax outflow areas enjoy the bottom-line tax revenue through “assignment”. Secondly, with the goal of fair opportunity, by changing the taxable connection and the multi-factor determination method, the tax outflow areas can obtain taxes that match their contributions. Finally, with the aim of fair results, the taxable connection rules should be improved through relatively precise quantification. When it comes to the tax system level, based on the current tax system structure in China, the key points of reform should be to establish a multi-region sharing principle of value-added tax corresponding to the value contribution structure, expand the identification methods of enterprise branches under the diversified model of the platform, and set up rules for the platform’s responsibility fulfillment and the withholding and remittance of digital virtual branches of employing enterprises. |
| keywords:platform economy divergence between tax revenue and tax sources regulatory limits regional tax distribution value creation structure |
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