Observation of international tax reform in the digital economy era

The digital economy is a key force for reorganizing global factors, reshaping the global economic structure, and changing the global competitive pattern. International taxation is one of the key hubs of global governance. The international tax reform of the digital economy is becoming the core issue of global governance reform. Here, the basic problems are re -observed to better solve the imbalance, inadequate, and irregular problems of the development of the digital economy, and realize its global deepening application, standardized development and inclusive sharing.

Data elements under the digital economy

The "Fourteenth Five -Year Digital Economy Development Plan" released by my country in 2022 clearly states that the digital economy is a key element with data resources, with modern information networks as the main carrier, and information and communication technology integration applications, and all elements digital transformation For the new economic form of important driving force, it can promote fairness and efficiency to be more unified. The essence of its essence can be obtained three basic judgments. First, the foundation of the rise of the digital economy is the relative surplus of the industrial economy. Since the 1980s, due to the rise of a large number of emerging industrialized countries, the marginal profit margin of the world economy has gradually declined, thereby forming relative excess production. Second, the digital economy is essentially a polymerization method characterized by "connectivity". Due to the relative surplus of production, in order to achieve the exchange value of industrial production, more users and consumers through information network discovery and connecting more users and consumers have historic motivation. Third, the characteristics of the digital economy are manifested in the effective consumption caused by the effective needs of production and life. In the era of digital economy, consumer -led economic circulation structure provides legitimate foundation and fair opportunities for the value contribution and income sharing of the demand party.

To observe the value of data element, its essence is to integrate the natural technical information and social institutional information of the interactive population through electronic coding to achieve diversified and multi -level supply and demand's echism, overallness, and scale connection. Behind the data empowerment, the potential of people's ability to use and consumption ability is ultimately activated. On the one hand, the data factor shows the integrity of value, because in the process of coordinated innovation in information technology products, application paradigms, business models, and institutional mechanisms, the technical information of different time and institutional information in different regions across timetable and space across time and space In particular, the consumers and users of the micro -counterparty as a producer, as well as the contribution of the government's consumer government in the exchange value. On the other hand, the data elements also show the scale of value, because its cross -space exchange value achieves the regional and time limit, and the maximum integration of the value exchange of interactive people is integrated. The realization of data elements in the digital economy's exchanging value of diversified and multi -level subjects is greatly different from the locality and temporary nature of the traditional factor effect. It must be required to scientific boundary and reasonable specifications of all links, use, and income of the data element. Essence

Digital economy forced international tax reform

The rapid development of the digital economy has impacted the current international tax rules system. Enterprises that provide digital products and services can operate cross -border operations and obtain income without having to set up entities in market countries, and then hoard huge profits at low taxes through the planning of intangible asset ownership, so that their global tax burden is at a very low level. Due to the restrictions on the current international tax rules, the digital economy market countries have no right to impose taxes on such foreign science and technology giants that have not established entities in their own countries and cannot obtain corresponding tax returns with their profits. As a result, the international community agreed that it is necessary to reform the current international tax rules system. After the game of all parties, OECD has formed a "dual pillar" solution to respond to economic digital international tax challenges under the tolerance framework. The purpose of the pillar is to increase the taxation rights of the market country. By modifying the existing cross -border income tax distribution rules, a part of the surplus profits of the super large -scale high -profile multinational enterprises are allocated to the market country; The effective tax rate of multinational enterprises in each jurisdiction has reached at least the world's lowest tax rate.

According to OECD forecasts, according to Pillar 1, the tax collection rights of more than 100 billion US dollars per year are expected to be re -distributed to the market jurisdiction. The amount of traditional industries is far greater than the amount of high -end industries represented by the digital economy; according to the pillar 2 two; The 15%global minimum tax rate is expected to generate an extra tax income of about 150 billion US dollars worldwide each year; with the "dual pillar" plan, all types of economies will benefit from more tax revenue, especially in the new crown pneumonia Under the economic background of the epidemic, these additional tax revenue will be welcomed by governments from various countries. However, as some scholars have pointed out, the overall increase in taxation of the plan has not fundamentally reversed the dilemma of global economic imbalances. The pillar weakened the taxes of high -end industries and increased the tax burden of low -end industries. The total tax amount coming to the pillar also shows that European and American countries have obtained more real benefits from this anti -taxation mechanism. It can be seen that under OECD -led tax base erosion and profit transfer framework, its digital tax reform scheme has obvious triple characteristics. With the advantages of the international community to challenge the digital industry advantages of the international community, the European Union protects the appropriate interests of taxation rights in its own market. However, at the same time, it has compromised with the United States privately to cover up and protect its increasing tax base between traditional industrial economy and developing countries. The interests of tax rights; the setting of the world's lowest tax rules dominated by Europe and the United States, which has a limited increase in the taxation of developing countries in nominal and short -term, but potentially and substantially suppressed the opportunities for the development of backward countries and emerging industries. The characteristics of the digital economy require an equal and fair economic structure. On the one hand, with a huge cross -space -time connection effect, the digital economy has continuously expanded the availability of many values ​​to all people, and produces natural inclusive results. On the other hand, the overall and scale effects of the digital economy are more likely to exacerbate the imbalance between the economy and the tax base, and it has also forced taxes to form a fair rule for correction. The essence of international trade and investment is an exchange of value. However, due to historical limitations, the distribution right of traditional advantage elements has imbalances in the profit level of micro -enterprise and at the macro national tax base level. The deepening development of the digital economy will drive the absolute advantage of market exchange based on the fact that the factors such as resources, technology, and capital will be corrected and balanced.

From the stock competition to incremental sharing

At present, the global digital economy shows the "three -party game" under the United States "digital hegemony". The United States relied on advanced advantages and technology reserves, and took the lead in establishing industry standards in the Internet and digital fields and occupying the huge share of the international market, forming a global "digital hegemony". China ’s digital economic strength characterized by digital technology and domestic market applications has continued to rise. The“ digital sovereign ”consciousness generated by the EU based on huge users' participation and market contribution is gradually awakening, which has directly challenged the United States’ “digital hegemony” to form numbers and form numbers. The world pattern of "one super two". In the field of digital economy and international taxation, competition for tax jurisdictions for market countries is a trend of subjective integration. The EU has become the main promoter of the "dual pillar" plan, and the US advantage is obviously conflicting with digital taxes; China is in the middle, and it has something in common with the United States in promoting the development of the digital economy to enable residents to enjoy better scientific and technological dividends, but with The EU has the same reform concept in promoting the balance of economic tax benefits. How to choose still needs to consider how to choose.

As mentioned earlier, the digital economy requirements adopt the concept of open cooperation, not only the data as the key element, but also to realize the deep integration of digital technology and the real economy to better meet the needs of different people; Industrial transformation and upgrading, cultivate new industries and new formats, and promote the sustainable and healthy development of the economy. However, the tax base erosion and profit transfer operation plan, as the most influential reform plan in the international tax field, whether it is the rules of the anti -tax avoidance of multinational companies in the 1.0 version, or the 2.0 version of the reform plan for the imbalance of the international tax base in the digital economy, Based on the inventory and competitive thinking, we adopt a micro and local observation perspective. On the surface, the formal economic order is promoted through balanced rules. In fact, we seek an economic pattern of monopoly competition. At this time, the principles of co -business, co -construction, and sharing that the "Belt and Road" initiative adheres to the specificization of the principles of discussions, co -construction, and sharing in the international tax field. The upgraded version realizes the incremental sharing order from the inventory of the inventory to the tax economy cooperation. Under the mechanism of co -construction and profit sharing of tax bases, the first is to promote the formal integrity of the international tax reform plan to expand the fair rules, design fair tax jurisdictions from the industrial economy to the digital economy, and realize the digital economy and the real economy Comprehensive tax base balance. Second, based on the "Belt and Road" initiative and the concept of the community of human destiny, advocate taxation co -construction and profit sharing, rationally treat tax benefits, help developing countries strengthen the construction of fiscal capacity, and truly promote economic growth in backward areas and the generals of emerging industries in the emerging industry. Benefit development.

(This article is the "Research on International Taxation Governance" (G2021115002L) in the later period of the National Social Science Foundation of the National Social Science Fund)

(Author Unit: International Tax Research Center of the Central University of Finance and Economics; Xiamen National Accounting Academy)

Source: China Social Science Network-Journal of Social Sciences of China

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