On the Tax Problems and Countermeasures in E-commerce

Abstract: E-commerce, as an important part of the Internet economy, sweeping the world economy at all levels, more and more enterprises have made huge profits. However, because e-commerce has the characteristics of digitalization, globalization and virtualization that traditional commerce does not have, it has caused an unprecedented impact on the tax principles and tax collection and management systems based on traditional trade forms, involving value-added tax, income tax, business tax and other taxes, highlighting many legal gaps and loopholes. At the same time, as a new way of business, e-commerce has made great contributions to China's economic development and has become a potential energy source for tax growth. In this paper, the international attitude to e-commerce and some legal issues facing the development of e-commerce in China are discussed, and the lack of taxation in e-commerce is systematically analyzed. Finally, the article puts forward some humble opinions on the development of e-commerce in China by combining the international advanced theory and practice with the actual situation of our country.

Keywords: electronic commerce tax law tax collection and management

E-commerce, as the business mode of advanced production in the information age, has the characteristics of intactness, concealment, virtuality, globality, network and digitality. On the one hand, the existence of e-commerce has promoted the actual economic growth and become a potential source of tax growth. On the other hand, e-commerce has challenged the current tax legal system, and the identification of permanent institutions and jurisdiction has fallen into a dilemma. In recent years, e-commerce taxation has become the focus of international society and domestic scholars.

1. the current situation of international e-commerce tax and the current situation of our country.

"The importance and support of a society to a certain emerging industry can often be reflected to a certain extent from its tax policy." [1] A series of tax issues brought about by e-commerce have attracted the attention of governments and international organizations around the world, and governments and international organizations have introduced tax policies and laws on e-commerce on the basis of the original tax policies and principles.

(I) United States

As the birthplace of e-commerce, the United States has become the world's most widely used in e-commerce, most of the world's e-commerce trade has occurred in the United States. Therefore, there are many policies on e-commerce in the United States, and these documents reflect the policies and attitudes adopted by the United States towards e-commerce.

In November 1996, the U.S. government published the first white paper discussing the taxation of Internet trade-"Selective Tax Policies for Global Electronic Commerce." The book puts forward several principles on the taxation of e-commerce: the principle of tax neutrality, taxation according to the tax jurisdiction of residents, avoidance of double taxation and improvement of tax collection management techniques. The document argues that, in accordance with the principle of tax neutrality, no new taxes or surcharges are introduced when formulating tax policies related to e-commerce.

On July 1, 1997, Clinton published the Global Framework for Electronic Commerce. This "Declaration of Independence", known as the United States has fully entered the information age, proposes to turn the Internet into a tariff-free zone, that is, to impose zero tariffs on import and export trade on the Internet. It is also recommended that Governments not only avoid excessive restrictions on e-commerce, but also try to help encourage enterprises to use the Internet to promote business development. Governments are also required not to impose new taxes on e-commerce, but to adopt unified tax measures under the existing tax system through the cooperation of various countries. [2]

In February 1998, in order to protect the United States' advantages in Internet technology and trade from being undermined by other countries' tax policies, Clinton delivered a speech on the "New Deal on the Internet" and announced three draft Internet trade tariff policies. At the same time, I also want to use the Internet to sell American products to every corner of the world, expand market share, and make the American economy more prosperous. [3]

In October 1998, the U.S. Congress signed the Internet Tax Exemption Act. The passage of the bill once again shows the American people that there will be no large taxes on e-commerce in the short term.

In May 2000, the U.S. House of Representatives voted to extend the Internet Tax Exemption Act for five years, extending the online tax exemption until 2006. [4]

In general, the United States does not advocate levying taxes on e-commerce.

(II) the European Union

As the scale of e-commerce development is slightly behind the United States, the European Union has a different view on whether e-commerce should be taxed. They believe that at least they can't be taxed. The EU believes that tax should have legal certainty, e-commerce should not bear additional taxes, but also can not be exempted from existing taxes.

In April 1997, the European Trade Commission issued the European Electronic Commerce Initiative. On July 8, 1997, the European Telecommunications Ministerial Conference attended by 29 countries adopted the Bonn Ministerial Conference Declaration in support of e-commerce, advocating that officials should minimize unnecessary restrictions and help private enterprises develop independently to promote Internet business competition. These documents initially set out the basic policy principles of the EU to create a "clear and neutral tax environment" for the development of e-commerce, and oppose the imposition of any form of new tax. The development of EU integration provides a good environment for the use of e-commerce, but EU integration strengthens the concept of tax residents, damages the principle of territoriality of taxation, and the competition for the most preferential tax treatment granted by EU member states to direct investment will become more intense.

On 8 June 1998, the EU published a report on the protection of value-added tax revenues and the promotion of electronic commerce. The following year, the European Commission announced the tax guidelines for online transactions: no new taxes and surcharges, so that the existing taxes to adapt to the development of online transactions. In the case of value-added tax, the principle of tax neutrality is ensured for electronic transmission as a service. Intangible assets, such as music and software, provided to EU individuals in online form by countries outside the EU must be taxed in the EU to reduce the difficulty of taxing online traders, strengthen the management and enforcement of online transactions, and ensure the effective collection of taxes. In order to facilitate tax collection and administration, it is recommended to use paperless bills in online transactions and to adopt electronic VAT tax returns. [5] In June 2000, the European Commission published a VAT levy scheme for e-commerce, setting out the principles for the taxation of electronic transmissions. Suppliers of electronic delivery services in the same EU country must be taxed in that country. If an electronic transmission crosses two EU countries, it is taxed in the EU country where the supplier is located. Suppliers from non-EU member states who provide electronic transmission services to EU member states are subject to VAT. At the same time, the supplier must be tax registered in one of the EU countries. [6] On July 1, 2003, EU regulations on taxation of e-commerce in non-member countries entered into force. The new regulations stipulate that companies in non-EU member states that sell books, software, and audio-visual products to individual consumers in the 15 EU countries through the Internet will pay value-added tax to the EU like other industries. The introduction of this regulation means that the taxation of Internet e-commerce has entered the implementation stage.

(III) the current situation of our country

China's online consumption started late, the level of development is also low, so far has not yet formed a fixed market, consumers' online consumption also has a greater randomness. Therefore, the impact of e-commerce on China's tax revenue is not obvious, but the lack of taxation of e-commerce from all walks of life has also given great attention. However, at present, the design of China's tax system has not yet made clear provisions on online transactions, let alone taxing e-commerce activities.

2. the tax problems in China's e-commerce

While e-commerce brings convenience, efficiency and wealth to human society, it also poses a severe challenge to the effective tax legal system of our traditional industry. The impact of e-commerce on China's current tax law is mainly reflected in the tax principles, permanent institutions, tax jurisdiction and tax subjects and tax objects.

Whether (I) should levy e-commerce tax

Like other developing countries, China's e-commerce is in the stage of development, the share of the national economy accounted for very little, but the growth momentum of its transactions is very rapid. Therefore, a tax on electronic trade will become a double-edged sword, on the one hand, the development of e-commerce has brought a lot of economic flow to our country, no tax, it will cause tax loss, financial losses. On the other hand, e-commerce is a new technology industry, its development is not stable, and taxing it is likely to curb its healthy development. There has been much discussion about whether e-commerce should be taxed or exempted.

In response to this issue, domestic scholars have different opinions. Those who agree to include e-commerce in the scope of taxation believe that: First of all, the behavior of transactions through the Internet is only a high-tech method to transform the past tangible transactions into invisible on the Internet. However, its essence has not changed, and it still conforms to the tax scope stipulated in my country's "Constitution" and "Tax Collection and Management Law. Secondly, taxing e-commerce is the need to adjust the national economic order. As a sovereign state, citizens have ex officio jurisdiction over economic relations between foreign companies and our companies. And taxing e-commerce is conducive to protecting the country's fiscal revenue. Moreover, due to international pressure, e-commerce should also be taxed. E-commerce in the European Union and Japan is relatively developed, and the issue of taxation of e-commerce has not only been put on the agenda, but has also entered a substantive stage of operation. China is basically a net importer of e-commerce, so it is more urgent to tax it and strengthen its control. [7] Those who hold a negative attitude mainly believe that e-commerce is a new industry in our country, and its development needs strong support. Now the introduction of e-commerce tax is not conducive to promoting economic development. At least no new taxes. Some scholars believe that, like the introduction of new taxes on traditional business trade, it will increase social costs and cause social welfare losses.

The impact of (II) e-commerce on tax principles.

The basic principles of taxation include: the legal principle of taxation, the fiscal principle of taxation, the principle of fairness of taxation and the principle of efficiency of taxation. [8] First, the main elements of the statutory principles of taxation are the statutory principles of the elements of taxation, the principle of clarity of the elements of taxation and the principles of taxation and criminal law. Due to the rapid development of the Internet, as long as there is a computer connected to the Internet, e-commerce can be carried out at any time. According to the current legal system of our country, there are no provisions for taxpayers in e-commerce, tax rates and other tax elements, let alone clear. Secondly, the basic connotation of the fiscal principle of taxation is that the establishment and reform of a country's tax system must be conducive to the need to ensure the country's fiscal revenue. The principle has three requirements, tax revenue should be sufficient, the overall level of tax burden should be moderate and tax revenue is flexible. The rapid development of electronic trade has brought huge economic flows to the country and individuals, and if it is properly taxed, the tax base is expanded and the fiscal revenue is increased, which is in line with the principle of fairness and reflects the fiscal principle of taxation. Furthermore, the principle of fairness in taxation includes both horizontal and vertical equity. On the one hand, although e-commerce is a kind of digital trade of goods or services, it still has the basic characteristics of commodity trading and belongs to the taxable behavior of the current tax law. In accordance with the requirements of horizontal equity, it and traditional trade should be subject to the same tax laws and bear the same tax burden. On the other hand, from the perspective of the principle of vertical fairness, e-commerce, as a new industry in China, is in the stage of development. The profit of network trade is limited, which can be said to be far less than that of traditional trade. There is still an obvious gap between traditional trade and e-commerce in terms of tax ability, and it should be treated differently here. Therefore, the measures to tax but reduce the tax on e-commerce should be in line with the principle of horizontal and vertical fairness of the tax law, as well as the actual development of e-commerce in China. Finally, the principle of efficiency of taxation, its relationship with the principle of fairness is that efficiency gives priority to fairness. Taxes should not influence firms' economic choices of market behaviour and trade patterns, but should ensure that the market becomes the sole force determining the success or failure of trade patterns. At the same time, minimize the cost of taxpayers' pursuit. It is the embodiment of the principle of tax neutrality, which requires the market economy mechanism to play a regulatory role in the effective allocation of resources, while not leading to other economic losses or additional burdens on taxpayers. Therefore, in order to avoid hindering the development of new technologies, similar economic income should be treated equally in taxation, regardless of whether the income is obtained through electronic commerce or traditional commerce.

Determination of permanent establishment by (III)

A permanent establishment is a fixed place of business, including management and workplace, where an enterprise conducts all or part of its business activities, and it is the basis for the taxation of business activities by the tax authorities of various countries. [9]

To confirm a permanent establishment by material factors, the permanent establishment must meet the following three conditions: first, the enterprise must have a place of business to carry out business activities, second, the business activities of the enterprise are fixed in space and time, and third, the activities engaged in by the enterprise must be business activities other than preparatory or auxiliary activities. [10] The permanent establishments of traditional trade are fixed tangible entities and are well documented in the tax authorities, which may determine the subject of tax payment based on the permanent establishment of the enterprise. In e-commerce, the environment in which the transaction takes place is a virtual digital space with no physical organization, and the subject of the transaction can either lease or own a server in the country where the customer is located, or lease or own a server in a country other than the country where the customer is located. The foreign entities on both sides of the transaction do not have a fixed permanent establishment in the country of the customer, so that the tax authorities of the country of the customer are unable to determine where the transaction is being conducted under current tax principles, losing the tax basis, let alone taxation. Therefore, it is not feasible to use material factors as the judgment standard of permanent establishment in e-commerce. [11] When determining a permanent establishment based on human factors, it means that although an enterprise of a Contracting State has not set up a fixed place of business, it can still set up a permanent establishment because of the activities of its agent, as long as the business agent is a non-independent agent attached to the enterprise, and the enterprise authorizes the business agent to engage in business activities of a specific nature, such as authorizing its agent to sign contracts on behalf of the entrusted enterprise. [12] In e-commerce activities, however, when a foreign seller reaches an agreement with a network service provider to use or rent a network service provider's server to maintain a web site to carry out its sales activities, it is difficult to identify the latter as the former's business agent and cannot constitute a permanent establishment of the seller. Therefore, it is not feasible to judge whether there is a permanent establishment in the e-commerce environment by human elements.

Determination of (IV) tax jurisdiction

At present, most countries in the world have parallel source-of-income tax jurisdiction and resident tax jurisdiction. Tax on income from domestic and foreign sources of domestic residents and income from domestic sources of non-residents. However, the emergence of the Internet has blurred geographical boundaries. On the one hand, it is difficult to identify the location of service providers, that is, it is impossible to know the source of economic income. Service providers only need a computer that can connect to the Internet to apply for a domain name to participate in the transaction, and service buyers do not even need to apply for a domain name to participate in the transaction. Such arbitrary transactions directly lead to the inability to determine the source of income. On the other hand, the complexity of the identification of resident status has brought great challenges to the tax jurisdiction. With the continuous development of the network, e-commerce has a strong liquidity and uncertainty. It is difficult to determine the residence or residence time of both parties to the transaction. It is impossible to define resident taxpayers or non-resident taxpayers by traditional standards. The traditional tax jurisdiction is also used to tax business, which will cause the problem of double taxation.

Determination of Tax Subject and Tax Object of (V) E-commerce

In traditional business trade, operators usually have their own place of business, and in the tax authorities have registration, as the object of taxation, property and behavior are tangible, the tax subject is simple and clear, objective and well documented. However, under the e-commerce mode, transactions are carried out through the network. On the one hand, the information of the tax payer exists in electronic form, and the vouchers and information of the transaction can be easily modified, even leaving no trace, which directly affects the vouchers of tax collection and management. On the other hand, the tax payer has no fixed business place and relies entirely on the network to conduct transactions, they can achieve the effect of avoiding the jurisdiction of the tax authorities by frequently changing the website, and the information used in the registration of the tax subject may also be false, which brings inconvenience to the tax collection and administration. Therefore, the website cannot be used as the sole basis for identifying the subject of taxation.

In the e-commerce environment, the criteria for dividing taxes have been destroyed, and the boundaries of various taxes have been blurred due to the unclear taxation objects. For example, when trading electronic products online, non-resident enterprises transmit digital products to buyers in China through the Internet. The act can be considered either the provision of services, the sale of intangible goods, or the use of concessions. If it is considered to be the provision of services, it is subject to sales tax; if it is considered to be the sale of intangible goods, it is subject to value-added tax and income tax; if it is considered that these data are used specifically for the development of procedures for customers and are Chilean property, they shall be regarded as concessions. [13] In addition, the model of electronic trade has made it more difficult to identify the subject of taxation. The emergence of e-commerce has changed the relationship between logistics, capital and information flow in the traditional trade model, forming a new form of trade, online transactions and offline transactions. In the case of online transactions, the whole process of transactions is completely networked, so that logistics, capital flow and information flow are merged into one, which has caused a considerable impact on the distinction of tax objects. Offline transactions, with the characteristics of traditional trade, the subject matter is transmitted in reality, according to the subject matter to identify which kind of tax object it belongs to, does not affect the determination of the tax.

3. perfect the tax countermeasure under the electronic commerce

As mentioned above, China's e-commerce is at the stage of development, and there is no special tax law for e-commerce. The state has only issued some supportive and encouraging policies. For example, in the "Several Opinions on Accelerating the Development of China's E-commerce" issued by the state in early 2005 [14], it is clearly pointed out that the Ministry of Finance and the State Administration for Industry and Commerce are requested to further discuss the implementation of the "Several Opinions, measures are proposed for tax relief for e-commerce enterprises. Currently, the state is tax-free for online transactions. In recent years, the state's attitude towards personal e-commerce is to promote rather than restrict, and there is no tax in a short period of time. But there have also been signs that the authorities have an intention to tax it. For example, in 2006, the Ministry of Commerce issued the "Guiding Opinions of the Ministry of Commerce on Online Transactions" [15] for soliciting opinions, which stated that individuals opening online stores must be registered in the industry and commerce and must pay 4% value-added tax. At the same time, the Ministry of Commerce also admitted that the opinion is not legally binding, similar to the Convention on Civilization, but only encouraged but not enforced.

In view of the above analysis of the current e-commerce tax problems, the author puts forward the following suggestions:

(I) correctly handle the current tax law and e-commerce issues

Since e-commerce is a business act, it should be taxed. The rule of law society requires that taxation be governed by law. In order to make taxation of e-commerce legal and better solve the problems caused by this new transaction method, normative provisions on e-commerce taxation should be added to the current tax law. On the premise of not adding new taxes, the provisions of e-commerce should be added to the laws and regulations of taxation, and the concepts of permanent establishment, source of income, goods, services and concessions should be redefined according to the characteristics of e-commerce, so as to include e-commerce, so as to improve the current legal system of tax law in China. However, before the tax law makes appropriate amendments, supplements, redefinitions and interpretations, it should also be based on the principle of encouraging the development of e-commerce, to give e-commerce some preferential tax policies, such as temporary exemption of e-commerce tariffs, the value-added tax rate of online transactions to implement a low tax rate system.

(II) recommendations based on tax principles

Although e-commerce brings a great shock to the principle of statutory, fiscal, fair and efficiency of taxation, it does not mean that the principle of taxation is out of date. According to the existing tax principles, the tax law should be continuously improved, and the connotation of the relevant concepts and norms of e-commerce should be revised and supplemented.

First, the statutory principle of taxation. According to this principle, there is no express provision in the law not to pay taxes. Under the current economic conditions of our country, no new taxes should be imposed. Encourage and stimulate the development of e-commerce. When the time is ripe, a new tax law will be introduced to levy a special tax on e-commerce. Second, the principle of fairness in taxation. According to the principle of fair tax burden, the taxation of e-commerce enterprises should also be given the same tax treatment as other traditional enterprises, especially because enterprises operate e-commerce business and increase their taxation. However, in the early stage of the development of e-commerce, some preferential tax policies are given to e-commerce enterprises, because e-commerce represents the development trend of future trade and needs certain policy support. [16] Furthermore, in accordance with the principle of tax efficiency, costs should be kept to a minimum in the taxation process. In the formulation of e-commerce tax collection and management measures to take into account the full use of the advantages of the Internet, to promote the modernization of tax collection and management means, so as to improve the efficiency of collection.

Recommendations of the (III) for a permanent establishment

As mentioned earlier, the traditional permanent establishment judgment standard does not apply to electronic commerce. Just as some scholars think, "we should break through the traditional concept that non-residents have some kind of fixed or tangible physical existence in the territory, as the premise of the source to exercise the jurisdiction of taxation, and seek the source tax connection factor that can better reflect the economic transaction connection and business essence in the era of network digital information economy, it is not appropriate to try to explore the existence of e-commerce transactions in the traditional framework of the concept of those fixed, tangible physical existence of the mark." [17]

First of all, in view of the current development of e-commerce, scholars should be organized as soon as possible to redefine permanent establishments according to the generally accepted practice in the world, eliminate their requirements for "fixed places of business", and make provisions on the scope of some related concepts, such as, the website server automatically completes advertising, ordering, etc. into the "scope of business activities". Secondly, improve the tax collection and management law, increase the tax collection and management of electronic trade. Third, increase international cooperation and strengthen tax collection and management of transnational e-commerce.

(IV) other suggestions

Improve the current tax collection and management law. First of all, we should establish a special e-commerce tax registration system and e-commerce tax declaration system, and bring e-commerce into the scope of tax collection and administration law. In order to facilitate tax returns, a digital identity system and an electronic invoice system should also be established, a system of filing and separate accounting for e-commerce should be implemented, and a financial software filing system should be strictly implemented. Secondly, independent fixed tax rates and flat tax bills should be adopted to distinguish them from other tax bills. A system of withholding and payment by banks in the place of consumption can also be implemented. And the establishment of e-commerce inspection system, tracking and monitoring system, electronic investigation system and strict punishment system. [18]

Set up a corresponding body to study the legal issues of e-commerce taxation. The research institution on legal issues of e-commerce taxation can be established by the State Administration of Taxation in conjunction with the Ministry of Information Industry and the Ministry of Finance. Mainly responsible for tracking the development direction of e-commerce and research on the legislative issues of e-commerce taxation around the world. Comprehensive development in line with China's national conditions of e-commerce tax guidelines. The formation of a viable e-commerce tax legal system. Coordinate international e-commerce tax legislation. [19]

Improve other existing tax laws. Addition of e-commerce taxation regulations and addition of relevant e-commerce provisions in other relevant laws. For example, adding e-commerce provisions to the financial law, registering accounts under real names, strengthening the contact between the tax bureau and banks, and tracking customer information.

[1]http://www.ctax.com.cn/fask/20011126213457.htmVisited on 12 June 2009

[2] Mei Yuxin, "A New Cyber Deal Across Transit-The U.S. Government's E-Commerce Development Policy", in International Trade, No. 1, 1999, p. 15

[3] Clinton's New Deal on the Internethttp://news.chinabyte.com/439/1225439.shtmlVisiting on 3 June 2009

[4] Internet Tax Exemption Act,http://www.gseis.uela.edu/iclp/itfa.htm

[5] "E-commerce Laws and Regulations" Wang Jiping, Li Dajun, Tsinghua University Publishing House, September 2002 P 164

[6] European e-commerce initiativehttp:// www.eordis.Lu/esprit/sre/ecom.htm: 1997Year.

[7] "Research on Several Topical Issues of Electronic Commerce Law" by Li Shuangyuan and Wang Hailang, Peking University Press, December 255-256, 2003

[8] Xu Jianguo, Xue Gang, Editor-in-Chief, Tax Science, August 2005, Economic Science Press

[9] International Tax Law, 2nd Edition, edited by Liu Jianwen, Peking University Press, April 2004

[10] "Electronic Commerce and Law" edited by Tan Zhengyue Ping Tian Wen Ying People's Posts and Telecommunications Press, March 45-46, 2001

[11] Hu Hai, "The Impact of Electronic Commerce on the Legal System of Tax Collection and Administration", published in Journal of Central South University of Forestry and Technology (Social Science Edition), Volume 1, No. 2, July 2007

[12] "Research on Several Topics of Electronic Commerce Law" by Li Shuangyuan and Wang Hailang, Peking University Press, December 265-267, 2003

[13] "E-commerce Laws and Regulations" by Wang Jiping and Li Dajun Tsinghua University Publishing House, September 159-161, 2002

[14] Arimus interprets my country's first policy document on e-commerce-"Several Opinions of the General Office of the State Council on Accelerating the Development of E-commerce"http://www.chinaeclaw.com/blog/more.asp？name=alamusi&id= 34 & 页码 = 3

[15] Full text of guidance issued by the Ministry of Commerce on online transactionshttp://tech.sina.com.cn/i/2007-13/09161413033.shtml

[16] "E-commerce Law" by Wu Weiguang, Tsinghua University Publishing House P217

[17] Liao Yixin, "International Tax Legal Issues of Transnational Electronic Commerce and China's Countermeasures", in Southeast Academic, No. 3, 2003, 10.

[18] Huang Yandian. Fiscal and Tax Reform and Exploration in the Transition Period of Economic System [M]. China Financial and Economic Publishing House, 2002.232.

[19] Huang Yandian. Fiscal and Tax Reform and Exploration in the Transition Period of Economic System [M]. Medium

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(This article won the 2009 National Lawyers Forum excellent papers)