On The Perfection Of Value-added Tax System For Loan Services Of China’s Commercial Banks

Since China fully implemented the "business-to-increase" policy in 2016,the value-added tax reform has been a hot topic in academic and social discussions.The value-added tax system of commercial bank loan service should not only follow the general provisions of the basic value-added tax system,but also have difficulties in applying the value-added tax system due to its own transaction characteristics.At present,there is no uniform definition or classification of financial services in the world.Each country or region defines its own concept and types of financial services in line with its own characteristics according to its own actual situation,including commercial bank loan services.There is no uniform standard for the identification of commercial bank loan services,which mainly includes general loan services and credit card related services.General loan service revenue appreciation generally includes three values: intermediary service fee,risk compensation representing default risk and pure interest payment.The uncertainty of risk compensation brings difficulties to the recognition of value-added tax in commercial bank loan service,which in turn urges some countries and regions in the world to adopt the attitude of exemption from value-added tax for commercial bank loan service.At present,value-added tax is levied on commercial bank loan services in China.In the current environment,the value-added tax system of commercial bank loan services is different from the statutory principle of taxation in legislation,the definition of the scope of value-added tax is still doubtful,and the related tax laws have theoretical problems of unclear interpretation and unreasonable methods.In the market of commercial bank loan services,there are practical problems of increasing tax burden,violating the principle of tax neutrality,uncertain value-added amount,breaking the deduction chain of value-added tax,and unreasonable distribution ratio of central and local fiscal revenue,which urgently need to be improved.However,many countries or regions in the world have some advantages to learn from in terms of legal principles,implementation feasibility and tax administration cost saving,for example,the legislative method adopted by many countries or regions in terms of policy objectives,which focuses on the application of a certain function of the tax law according to their national conditions,the "principle+list+cover" model adopted in the legislative text,and the legislative method in which the transaction substance is judged as a supplement,the calculation model of deposit and loan interest difference tax base adopted in the design of the actual value-added tax system,and the deduction mechanism for partial deduction of input tax.Therefore,on the basis of understanding our country’s reality and learning from international excellent experience,we should perfect our country’s commercial bank loan service value-added tax system from the following four directions: First,we should perfect the relevant basic tax theory,adhere to the dual functions of tax revenue and economic regulation,implement the principle of tax legality and make good use of legal interpretation to solve the legal application problems that innovative commercial bank loan services may encounter;The second is to improve the method for determining the scope and tax base of value-added tax,taking the loan service of commercial banks as an example,using the "principle+list+cover" model,with the transaction substance as a supplement,and the method for determining the tax base based on the interest difference between deposits and loans;The third is to improve the VAT input tax deduction mechanism and collection and management measures for commercial bank loan services,adopt the method of deduction based on the proportion of total business volume and seize the development opportunity of the digital economy,and start with the electronic invoice reform to promote the role of tax big data collection and management measures;Finally,the central and local tax revenue distribution ratio should be optimized to reflect the proportion of the difference in tax revenue level and structure between the eastern and western central regions of our country and redistribute the central and local tax revenue.