First, the high-tech industry to encourage independent innovation to promote the development of a comprehensive evaluation of enterprise income tax policy
一、对鼓励自主创新促进高新技术产业发展的企业所得税政策的综合评价
New Corporate Income Tax Law in terms of tax incentives to encourage independent innovation and reflects the development of high-tech industry support. Article 27 provides that: meet the conditions for technology transfer income, and may be exempted or reduced corporate income tax ; Article 28 states: countries need to focus on supporting high-tech enterprises , reduced 15% enterprise income tax : The first thirty states: the development of new technologies, new products , new technology research and development expenses may occur in the calculation of taxable income when the additional deduction ; Article 31 : venture capital enterprises engaged countries need to focus support and encourage entrepreneurship investments can deduct a certain percentage of the amount invested enterprise income tax . Article 32 : corporate fixed assets due to technological advances and other factors . Require accelerated depreciation , and can shorten the depreciation period or take accelerated depreciation method . This is the biggest change is that the United Kingdom for the first time in the new enterprise income tax law in terms of tax incentives for venture capital to make regulations.新企业所得税法在税收优惠条款中体现了鼓励自主创新以及对发展高新技术产业的支持。第二十七条规定：符合条件的技术转让所得，可以免征、减征企业所得税；第二十八条规定：国家需要重点扶持的高新技术企业，减按15%的税率征收企业所得税。
Newly introduced , such as " Ministry of Finance State Administration of Taxation on enterprise technology innovation enterprise income tax preferential policies concerning the notice" ( Cai Shui [ 2006 ] No. 88 ) and " on the promotion of venture capital enterprise development tax policy notice" ( Cai Shui [ 2007 ] 31 No. ) and other documents on the original tax policies to promote technological innovation has been modified and supplemented. In addition, many places according to the local characteristics of economic development with local technology development strategy to develop a series of high-tech industries to encourage independent innovation to promote the development of tax policy. More representative example, encourage the use of information technology to transform Shanghai preferential tax policies : Beijing cultural and creative industries to encourage the development of tax incentives ; Suzhou Industrial Park to encourage the development of advanced technology-based service enterprises preferential tax policies and so on.
此外，许多地方也根据当地经济发展的特点结合本地的科技发展战略制定了一系列的鼓励自主创新促进高新技术产业发展的税收政策。While the existing preferential tax policy design of the system than in the past has been a big improvement , but there are still some problems to be solved .
First, R & D tax incentives applicable range of industries not clearly defined . There are no new Enterprise Income Tax Law on the development of new technologies, new products, new technology research and development expenses occurred additional deduction of discount applicable range of industries to be clear. From the central and local governments enacted tax policies to encourage independent innovation point of view, the following items can enjoy additional deduction of R & D spending tax incentives : industrial design and software development ; major maintenance and technical upgrading projects ; use of information technology ; cultural and creative ; advanced technology-based services. Practice for the identification of R & D activities are not uniform , research and development activities may occur in agriculture, manufacturing , software , services , and social sciences and humanities , what kinds of industries , which areas can enjoy tax incentives to encourage technological innovation need to be clear .
Second, the technology development costs included in the specific content is not clear enough , the actual lack of maneuverability . Technology development costs should be clearly recognized there are several issues : First, technological development to determine the place of occurrence . Whether only in the laboratory or research and development activities conducted by the Centre additional deduction is consistent with the requirements of the production line occurs whether additional deduction of R & D activities . Two is paid to a third party technology development fee you enjoy additional deduction of tax breaks. Third, technological innovation, industrial upgrading of the specific research and development projects , product improvement and process improvement , such as whether you can apply for the additional deduction . Fourth, technology development costs are recognized as an intangible part is entitled to additional deduction benefits.
Third, with the different stages of development of high-tech enterprises preferential tax system is not perfect . The development of high-tech enterprises are generally divided into four phases: research and development stage , development stage of development , maturity , which correspond to the technical life cycle : basic research and applied research, experimental development and prototyping , scale, technology transfers. Speaking from the enterprise level , the existing tax incentives fails to characteristics of the development stage of business development , R & D activity level speakers from the existing tax incentives not according to the technical development of the stage characteristics of its effective encouragement. The cumbersome tax incentives , lack of systematic and normative , the overall goal is not clear enough incentives , poor co-ordination of various preferential .
Fourth, the high-tech enterprises inside and outside the park for tax policy differences lead to unfair competition between enterprises . Britain currently only type of state-level high-tech industrial development zone science and technology industrial park will have 53 . Also set up their own local high-tech development zone. Some encouraging the development of high-tech industry tax incentives only in the high-tech development zone enterprises registered in order to enjoy , which brings two levels of tax injustice. First , the local high-tech development zone of preferential tax policies are not consistent formulation , which resulted in a high-tech park with preferential tax because of the different levels of local produce different. Secondly, the high-tech high-tech enterprise outside the park can not be contrary to the application of preferential tax policies to encourage technological innovation 's overall policy objectives , it will result in the region registered outside business situations. Give tax administration has also brought some obstacles .
Fifth, tax incentives approval management mechanism is not perfect . In the tax practice, where there is intense between tax competition , some local governments to attract capital, technology , the formation of local advantages , extend the exemption period to develop ultra vires , reducing tax rates and other tax incentives , and for high-tech companies do not have a recognized qualification effective review mechanism , resulting in a high-tech enterprise companies competing sectors accreditation efforts , resulting in the implementation of incentive policies ineffective . In tax incentives to encourage technological innovation abuse , while there is still not in place to implement preferential tax policies for the problems . As the UK tax base growth plan or by way of determining , indeed lack of rationality, often also additional taxes at the end of the task . This makes some of the sources of tension where the lack of publicity to implement tax incentives enthusiasm and initiative , or publicity is not in place , or are too strict examination and approval to the offer , resulting in enterprises should not enjoy tax incentives.
Second, to encourage independent innovation to promote the development of high-tech industry enterprise income tax policy design recommendations
Tax incentives to promote technological development as an important complementary measures is the established policy of the target service . Corporate income tax preferential policies to encourage independent innovation main goal is to create equal competitive business environment , and improving the capability of independent innovation , promote the development of high-tech industries , and enhance the international competitiveness of domestic enterprises and an area for the UK to become the first choice of multinationals create conditions for R & D base .
( A ) develop objective and transparent rules of R & D tax incentives
In the UK in the current tax incentives not yet clear which activities can be classified as R & D activities to enjoy and Technological fee plus the net benefits. Economic Cooperation and Development (OECD), developed by the Frascati Manual . That the R & D activities include manufacturing, software , services, social sciences and humanities fields activity. Most of the world countries, none of the social sciences and humanities classified as preferential activity. Beijing to develop tax incentives . Encouraged by cultural and creative enterprises belong to the social sciences and humanities activities . Preferential tax policies should be in the service industry , social sciences and humanities research and development activities can be enjoyed preferential clear . Otherwise it will become a GSP preferential tax policies . Would not achieve the established incentive , difficult to estimate tax expenditures may exceed the tolerance range finances .
On technology development costs plus the net preferential some specific issues should be further defined . First, technological development took place should not be confined to laboratories and research centers , research and development activities will take place in the production line , so regardless of technological development took place where R & D spending as long as the additional deduction shall apply . Secondly , the payment to a third party technology development costs should be allowed to enjoy additional deduction of tax breaks. Otherwise, companies developed their own research and development and outsourcing business to ask for selection due to tax incentives to be distorted. Thus have an impact on the overall economic efficiency . Not every business needs to carry out independent research and development , R & D capability of enterprises do not have the technology development needs of the subcontract , but will bring higher economic efficiency. Tax incentives should be designed to minimize the impact of economic activities of the enterprise . Furthermore, the proposed technological innovation, industrial upgrading of the specific research and development projects , product improvement and process improvement , also classified as research and development expenses for the additional deduction benefits. This will be more conducive to business innovation and transformation of old industrial bases tradition . Finally , all companies should be allowed to meet the requirements of technology development costs plus the net , including the part recognized as intangible assets and provisions have been enjoying the additional deduction in subsequent lives of intangible assets are no longer amortized .
( Two ) stage of development for the characteristics of high-tech enterprises preferential tax system design appropriate
In the corporate R & D and product development stage requires a lot of investment in R & D costs , companies no operating results, generally at a loss. Currently able to play on this stage there are tax incentives technology development fee plus deductions and accelerated depreciation of fixed assets deals . However, due to lack of tax deductible in the year specified in the part of the deferred period of not more than five years, the age limit so companies can not fully enjoy the tax benefits at this stage . Product development in the enterprise to its investment in the production stage, a large number of expenditures for the purchase of production equipment, technology continues to develop , product marketing. Corresponding tax benefits have technology development costs plus the net , accelerated depreciation of fixed assets , domestic equipment investment tax credit , net of employee education expenses and income tax exemption limit concessions . Under the new CIT Law, high-tech enterprises preferential tax rate of 15 %, then when the entity has taxable income , which consists of the actual plus enjoy preferential tax deduction is only 15% × 50%: 7.5%, tax preferential intensity is limited . Domestic equipment investment tax credit because they do not comply with WTO rules is likely to be adjusted.
Therefore, the development of high-tech enterprises should be based on the characteristics of the tax incentives to focus on research and development stage and high-tech achievement transformation stage incubation system and support for innovation . Improve technology development costs plus the net proportion of less than the deductible portion of the year to extend the deferred deadline. Will purchase a policy of state-owned equipment investment tax credit to companies to buy up to a certain technical standard equipment can enjoy the preferential investment credits and extended credit terms. Allow qualified enterprises according to their proportion of sales revenue extraction technology development fund , the establishment of scientific and technological development reserve system . As venture capital business operations and technology innovation cycle to adapt, better able to promote independent innovation activities, especially in favor of high-tech achievements transformation . Therefore, to encourage venture capital to establish and improve the operation of enterprises preferential tax policies .
( Three ) the use of scientific management mechanism to better achieve the goal of tax incentives
Strengthen tax administration and supervision mechanisms . Tax plan should be developed as soon as possible legalization procedures to avoid unplanned additional tax tasks. Emphasizes the principle of tax law , shall implement the various tax incentives. Encourage technological development in the long-term stable tax policy , local preferential policies on the basis of relatively uniform , consider appropriate delegation Tax Legislation , the local situation according to local technological development and technological characteristics of the industry to develop appropriate tax incentives , but to the right place permission to be clear , strict examination and approval filing system, the establishment of monitoring mechanisms to prevent abuse of preferential policies . Establishment of science and technology , finance, taxation and other departments of communication and coordination mechanism, improve the high-tech enterprises of the review system to avoid misnamed enterprises or projects tax benefits resulting national financial waste .
Try to encourage independent innovation to promote the establishment of high-tech industrial development tax expenditure budget performance , the use of cost - income approach for performance analysis of tax expenditures , tax expenditures for technological and scientific decision-making to provide an objective basis for total control .