論文摘要 隨著網路商業的快速發展與網路交易金額的急速增加,許多傳統的有形商品與專業服務亦紛紛開始利用電子商務的銷售管道,使得是否可對電子交易課稅與如何課稅的問題,乃成為國際間關切的目標。本研究目的試著能就電子商務對加值營業稅之影響,作一較完整的研究探討,希望能給政府部門施政計劃,提供參考建議。 賈志豪(民八十九年),其研究顯示我國1999年度電子商務下營業稅稅收損失達3.8億元。而本研究依據其研究方法及假說所計算出我國2000年度電子商務下營業稅稅收損失更是高達11.2億元,其稅收損失大幅增加了近200%。電子商務目前雖然仍處於發展初期,對於租稅管理及稽徵尚未有直接而顯著的衝擊,若未來電子商務規模正如預期般地急速成長,勢必影響政府加值稅稅基。 本研究發現電子商務之特殊性質,不但對現行之課稅觀念與稽徵技術形成衝擊,也為政府之賦稅收入造成影響,不過網際網路的新興科技亦帶來提升納稅服務之新契機,有助於降低稅務行政成本與納稅人之租稅依從成本。另OECD所提出的五種因應機制,本文認為電腦軟體自動扣繳制所面臨的阻礙最低,若能配合金融機構扣繳制度,可以在最小的執行成本下,完成加值稅的稽徵,並取得最完整的交易稽核軌跡,因而建議此機制可以做為政府未來制定租稅稽徵體制的參考。 本研究的建議大致可歸納為:政府應對於商業網站之管理,制定合理的規範準則,明定電子商店之網頁應明白標示商店之身份資料。稅捐機關宜採獎勵的方式,以提高納稅人運用網路申報之意願。我國目前推動之電子發票僅限於B2B部分,B2C部分不在試用範圍內,使得B2C稅收之損失更是雪上加霜,故應及早推廣電子發票適用於B2C交易。處在產品生命週期短促的網際網路環境中,政府在擬定電子商務政策時應該要嚴守分際,切不可因為畏懼技術擴散而處處設限,到頭來不僅抑制民間企業蓬勃的創意能量,更延誤了國家未來的發展契機。
Abstract Following the rapid development of web commerce and the booming increase in transaction amount through the net, e-commerce is widely adopted by conventional industrial sectors in tangible goods and by professional services ; as a result , the eligibility of imposing fax onto e-transactions and how to impose the fax have turned to be the goals of worldwide concern. The present study aims at conducting a more thorough research and exploration on the Influence of e-commerce to Value-Added Tax (Income Tax) and wishes to provide the results as reference or suggestions to the government . A loss in business income tax revenue up to 0.38 billion N.T.Dollars in Fiscal Year 1999 in Taiwan resulted from e-commerce was found in the study by C.H.Chia (2000). While the present study, based on the research methods and postulation of Chia(2000) , finds a rather serious loss in business income tax revenue resulted from e-commerce in Taiwan in Fiscal Year 2000 alone, and thus the fax revenue loss increases rather shockingly to 200% . E-commerce, being still at its infancy, has no direct or obvious impact against taxation and tax administration as so far; however, if e-commerce grows and expands rapidly as expected, it will absolutely affects the foundation of VAT by the government authorities. The present study discovers the characteristics of e-commerce and such features not only form an impact to taxation concept and auditing techniques but also result in major influence against the national revenue from taxes. Furthermore, the rise of new techniques in internet / the net also invites an unique opportunity for promoting taxation service levels, which helps in cutting taxation administrative cost and the taxation subordinate costs. Further, among the strategies presented in OECD, the Technology-based and/or Technology-facilitated option is assumed to confront minimal obstacles through the present study; should Technology-based and/or Technology-facilitated option be facilitated with the withdrawal mechanism of Collection by third parties, VAT collection will be implemented at minimum implementing cost, and also provide the best track for transaction auditing. Therefore, it is strongly proposed to take the said mechanism as a valuable reference for the government agencies to establish an ideal taxation audit system. The proposals presented in the present study can be concluded as the follows in general : For adequate administration to commercial websites, the government authorities should establish reasonable and logical criteria and guidelines, to clearly require a web page of an e-business to expressively state the ID information showing the status of the business. The taxation agencies should promote the tax-payers will and interest of declaring tax via the net with encouraging / incentive measures. The e-invoice currently promoted in Taiwan is confined within B2B scope without B2C. AS a result, the loss in B2C revenue is therefore worsened, therefore, it is strongly suggested that e-invoice be applicable to B2C transactions. Under the global net environments featured with short life-span of any new product, the government agency should follow strict disciplines during formulating e-commerce policy not to set restrains unnecessarily in view of avoiding risks of aggressive expansion through technology, otherwise, not only the vigorous creativity in the private businesses will be inhibited but also the chances for the state to develop be ruined.