Exploring The Construction Of An Advance Ruling System For Taxation In China

As the world economy enters the era of globalization and international economic and trade activities take various forms,countries continue to improve their tax systems to close tax loopholes,which in effect increases the complexity of the tax system and brings tax uncertainty risks to cross-border investors.In order to improve tax certainty,the international common practice is to establish a tax advance ruling system.China’s economy has entered a new normal,economic development has been transformed and upgraded,the organizational structure and economic activities of market players have become increasingly diversified,and the number of complex tax-related issues has increased,which brings a lot of tax uncertainty risks.The establishment of a tax advance ruling system can enhance the certainty of tax law application,reduce the tax risks of taxpayers,improve the level of tax administration of tax authorities,help create a firstclass business environment,and promote the international and domestic double cycle.Compared with developed countries,China’s advance tax ruling system is still in the initial exploration stage.2012 saw the start of case practice of advance tax ruling by taxation authorities,and some local pilot systems have also emerged,but China has not yet established a unified advance tax ruling system.With the advancement of tax collection and management reform,the establishment of a tax advance ruling system has been put on the agenda to better serve market players,create a good business environment and effectively improve taxpayers’ sense of access and satisfaction.In order to enrich the study of China’s tax advance ruling system and promote the process of building this system,this paper summarizes the practical exploration of China’s tax advance ruling system,analyzes the problems of China’s tax advance ruling pilot and the causes of the problems,reasonably draws on international experience,and adopts the literature analysis method and case study method to elaborate how to build a tax advance ruling system in China.The article is divided into six parts,the first part explains the background and significance of the study,and compares the current research status of the prior tax ruling system at home and abroad.The second part elaborates the concept and theoretical basis of the advance tax ruling system.The third part introduces the development status of China’s tax advance ruling system,and selects Nansha District of Guangzhou,the "model district" of China’s tax advance ruling development,focusing on analyzing the development history of its tax advance ruling system and summarizing the experience and problems of its pilot system.The fourth part puts forward the problems of slow process,narrow scope and disguised tax planning in China’s tax advance ruling pilot project and analyzes the causes of the problems from four aspects.The fifth part introduces the establishment of overseas tax advance ruling system and the practice and experience of typical countries(regions)of tax advance ruling system.In the sixth part,on the basis of summarizing the problems of China’s tax advance ruling pilot and learning from the experience of overseas systems,proposes a two-step strategy for constructing China’s tax advance ruling system,and makes specific suggestions for the construction of China’s tax advance ruling system from three aspects: pilot exploration in the first place,legislative confirmation in the second place,and supporting measures to help.